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Enforcement Actions Broker-Dealer Waivers

White & Case LLP

New Orders Lifting Bars Signal Shift by SEC

White & Case LLP on

In recent months, the U.S. Securities and Exchange Commission has signaled a shift in its approach to applications to lift administrative bars that restrict participation in the securities industry. This suggests there is...more

Jackson Walker

SEC Adopts Sweeping New Private Fund Adviser Rules

Jackson Walker on

On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”), by a party-line vote of 3-2, adopted new rules applicable to investment advisers to private funds (“Private Fund Advisers”) that address transparency,...more

UB Greensfelder LLP

The (Possible) Benefit Of Self-Reporting And Internal Discipline

UB Greensfelder LLP on

Historically, one of the surest ways to get yourself permanently barred from the industry is to forge a customer’s signature on something. According to the pertinent Sanction Guideline, at a minimum, a forgery, that is, a...more

UB Greensfelder LLP

FINRA AWC Includes Waiver Of A Fine: Is This A Sign Of Good Things To Come?

UB Greensfelder LLP on

Way back in 2006, NASD issued Notice to Members 06-55, which tweaked the Sanction Guidelines to allow not just the size of the firm to be taken into consideration when determining the appropriate sanctions to be meted out,...more

Carlton Fields

Can “Bad Actors” Wave Goodbye to SEC Waivers?

Carlton Fields on

The SEC has been thinking harder before waiving automatic disqualifications that the federal securities laws and regulations impose on so-called "bad actors." Without such waivers, companies may be barred from, among...more

Goodwin

FINRA Fines Broker-Dealer for Failing to Apply Class A Sales Charge Waivers for Certain Eligible Customers on its Mutual Fund...

Goodwin on

On June 16, 2014, the Financial Industry Regulatory Authority, Inc. (“FINRA”) accepted a Letter of Acceptance, Waiver and Consent (the “AWC”) from Merrill Lynch, Pierce, Fenner & Smith Incorporated (the “Firm”) regarding an...more

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