News & Analysis as of

Financial Services Industry Self-Reporting

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

Moore & Van Allen PLLC

The Desk: May Edition

On April 17, 2025, as previewed in the Division of Enforcement’s (“DoE”) February 25, 2025, “Advisory on Self-Reporting, Cooperation, and Remediation”, the Staff of the Market Participants Division (“MPD”) laid the remaining...more

Jones Day

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

Jones Day on

On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

Morgan Lewis

CFTC Staff Issue Advisory on Criteria for Referrals to the Division of Enforcement

Morgan Lewis on

The staff of the US Commodity Futures Trading Commission (CFTC or Commission) on April 17, 2025 issued an advisory outlining the criteria the agency’s Market Participants Division, Division of Clearing and Risk, and Division...more

Husch Blackwell LLP

CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

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On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Advisory on Referrals to the Division of Enforcement

On April 17, 2025, three operating divisions of the Commodity Futures Trading Commission (CFTC) jointly issued an advisory to provide guidance on the materiality or other criteria they will use in deciding whether to make a...more

Jones Day

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

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The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

Seward & Kissel LLP

Financial Services Firm Affiliates Settle Five SEC Enforcement Actions for Allegedly Misleading Customers and Failing to Act in...

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Broker Dealers; Compliance Officers; Boards of Directors - Quick Take: The SEC recently settled five separate enforcement proceedings...more

Fisher Phillips

The Whistleblowing Just Got Louder: 8 Things Employers Should Do in Response to Feds’ New Whistleblower Awards Program

Fisher Phillips on

A new initiative rolled out by federal officials this summer can reward corporate whistleblowers with up to $30 million – which means it is incumbent upon your organization to step up your game when it comes to corporate...more

Vinson & Elkins LLP

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

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The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

Troutman Pepper Locke

CFPB Releases Blog Post Favoring Use of Self-Reported Cash Flow Data in Credit Underwriting

Troutman Pepper Locke on

On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more

Hudson Cook, LLP

CFPB Bites of the Month - Q&A with Lucy Morris: Takeaways from 10 Years

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. With July 21, 2021 marking...more

Vedder Price

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

Vedder Price on

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

Katten Muchin Rosenman LLP

FINRA Releases New Guidance on Credit for Extraordinary Cooperation

On July 11, FINRA released Regulatory Notice 19-23 (the Notice),1 which provides welcome details on the ways that firms and individuals can receive credit for extraordinary cooperation in connection with an investigation in...more

WilmerHale

FINRA Issues New Guidance on Cooperation

WilmerHale on

On July 11, 2019, the Financial Industry Regulatory Authority (“FINRA”) restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for “extraordinary cooperation” in...more

King & Spalding

Above and Beyond: FINRA Clarifies Its Approach to Assessing Extraordinary Cooperation

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FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more

Sheppard Mullin Richter & Hampton LLP

SEC Enforcement’s Annual Report Prioritizes Retail Investors, Cryptocurrency, Cybercrime, and Individual Accountability

The Enforcement Division of the United States Securities and Exchange Commission (“SEC”) recently released its annual enforcement report (“Report”) for fiscal year 2018. The Report reflects an increased focus on retail...more

Carlton Fields

Delicate FINRA Balancing Act: To Self-Report or Not?

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FINRA Rule 4530(a) requires member firms to promptly report certain enumerated events. Rule 4530(b) is less specific, with supplemental guidance advising that a firm should report when it concludes or reasonably should have...more

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