On May 15, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the Securities and Exchange Commission (“Commission”) released responses to frequently asked questions (“FAQs”) relating to crypto assets and...more
Key Points - - The SEC’s Crypto Task Force acknowledges past hostility toward digital assets and aims to create more sensible regulations. - Tokenized securities face complex regulatory challenges, including compliance...more
As a follow-up to our prior discussion in this area, this article addresses a recent exemption issued to the New York Stock Exchange ("NYSE") by the Securities and Exchange Commission ("SEC") that allows for increased trading...more
StraightPath Venture Partners, LLC and PMAC Consulting have recently reached settlements with the US Securities and Exchange Commission (SEC) following SEC enforcement actions against them....more
On December 16, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) requiring the electronic filing, submission, or posting of certain forms required under the Securities Exchange Act of...more
On November 21, 2024, a Northern District of Texas court ruled that the Securities and Exchange Commission had overstepped its authority when the agency had implemented a rule (the “Dealer Rule”) requiring a broader group to...more
The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more
On November 22, 2024, the Securities and Exchange Commission's ("SEC") Division of Trading and Markets issued a much-anticipated "no-action letter" ("2024 NAL") clarifying the application of amended Rule 15c2-11 under the...more
The U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Exchanges were active across a host of regulatory issues impacting fintech companies and broker-dealers during...more
On September 18, the Securities and Exchange Commission (SEC or the Commission) adopted amendments to Rule 612 (Tick Sizes) and Rule 610 (Access Fees) under Regulation NMS under the Securities Exchange Act of 1934, as amended...more
On September 4, the Securities and Exchange Commission (SEC) issued an order against three investment adviser firms for violating the whistleblower protections of Rule 21F-17(a) under the Securities Exchange Act of 1934. This...more
Over the last week, several registered investment advisers have received examination letters, issued from both the Securities and Exchange Commission’s national office in Washington, D.C., and from at least one regional...more
On February 6, 2024, the SEC adopted new rules under the Securities Exchange Act of 1934 (Exchange Act), to expand the scope of “dealers” and “government securities dealers” required to register under the Exchange Act, become...more
Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more
Section 3(a)(5) of the Securities Exchange Act of 1934 defines the term “dealer” to mean “any person engaged in the business of buying and selling securities . . . for such person’s own account through a broker or otherwise,”...more
Compliance Update for the week Ending April 5, 2024 - For our clients and compliance colleagues, this weekly update will give you a quick look at the latest regulatory developments. Enjoy!...more
Introduction - On 6 February 2024, the US Securities and Exchange Commission (SEC) voted 3-2 to adopt two new rules that significantly expand the definitions of a “dealer” and “government securities dealer” in Sections...more
On February 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted new rules – SEC Rules 3a5-4 and 3a44-2 (collectively, the “Final Rules”) – to further define the phrase “as part of a regular business” used in...more
Key Points - Last week, the SEC announced settlements with 16 broker-dealers, dually registered broker-dealers and investment advisers, and affiliated investment advisers in connection with their failures to maintain and...more
Section 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”) defines a “dealer” as “any person engaged in the business of buying and selling securities […] for such person’s own account...more
On February 6, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to the definitions of “dealer” and “government securities dealer” that would subject certain market participants acting as liquidity...more
Earlier today, the Securities and Exchange Commission in a 3‑2 vote adopted new Rules 3a5‑4 and 3a44‑2 (together, the Dealer Rules) under the Securities Exchange Act of 1934, as amended (the Exchange Act), that will define...more
Who may be interested: Registered Investment Companies, Investment Advisers, Broker-Dealers - Quick Take: The SEC settled charges against a firm and the former head of the firm’s equity syndicate desk, arising out of a...more
Who may be interested: Investment Advisers, Broker-Dealers - Quick Take: The SEC settled charges against a firm that allegedly prevented brokerage customers and advisory clients from reporting potential securities law...more
Recent SEC actions relating to the definition of “dealer” under the Securities Exchange Act of 1934 may enable the SEC to start cracking the whip over more persons who actively trade securities for their own account “as part...more