News & Analysis as of

Settlement Recordkeeping Requirements Enforcement Actions

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Paul Hastings LLP

The CFTC Is “in the Mode to Make Deals” (and Other Updates on the Commission)

Paul Hastings LLP on

Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more

Katten Muchin Rosenman LLP

CFTC Acting Chairman Pham Announces Effort to Quickly Resolve Recordkeeping and Reporting Investigations and Pledges Additional...

During her keynote address at the Futures Industry Association’s International Futures Industry Conference, BOCA50, CFTC Acting Chairman Caroline D. Pham announced a new effort to encourage market participants to resolve open...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OSH Law Primer, Part XI: Understanding and Contesting OSHA Citations: An Overview

This is the eleventh installment in a series of articles intended to provide the reader with a very high-level overview of the Occupational Safety and Health (OSH) Act of 1970 and the Occupational Safety and Health...more

Orrick, Herrington & Sutcliffe LLP

FINRA AWC details reporting failures

On January 27, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) addressing alleged violations committed by the respondent, retail market maker offering execution services to broker-dealers and member firm...more

A&O Shearman

SEC Enters Into Off-Channel Settlements With Twelve Additional Firms Prior To Leadership Turnover

A&O Shearman on

On January 13, 2025, one week before Chair Gary Gensler is expected to step down as Chair, the Securities and Exchange Commission (“SEC”) announced settlements with twelve additional regulated entities for alleged...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more

BCLP

SEC Enforcement Sweep Regarding Off-Channel Communications Nets 26 More Settlements and Over $390 Million in Civil Penalties

BCLP on

On August 14, 2024 the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against 26 SEC-registered investment advisers, broker-dealers and dually-registered broker-dealers and investment advisers...more

K&L Gates LLP

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

K&L Gates LLP on

Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

Ballard Spahr LLP

SEC Nears First Settlement With a Credit Rating Agency in Off-Channel Communications Sweep

Ballard Spahr LLP on

Summary - The Securities and Exchange Commission (SEC) is reportedly nearing a settlement with a nationally recognized statistical rating organization (NRSRO) over its failure to preserve certain credit-ratings...more

Goodwin

SEC and CFTC Send Powerful Message With $2 Billion in Fines Related to Social Media and Text Recordkeeping Lapses

Goodwin on

​​​​​​​The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more

Goodwin

Financial Services Weekly News - October 2015 #3

Goodwin on

Regulatory Developments: FINRA Requests Comment on Rules Relating to Financial Exploitation of Vulnerable Adults - On Oct. 15 FINRA published Regulatory Notice 15-37, requesting comment on proposed amendments to...more

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