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The Countdown Is On! Building a Reg BI Compliance Program as Deadlines Loom

On June 5, 2019, the SEC adopted a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with broker-dealers and investment advisers. The focal point of this...more

The SEC Adopts Security-Based Swap Rules Governing Capital, Margin and Segregation

On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...more

FINRA Issues New Guidance on Cooperation

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

SEC Adopts Significant Changes to Regulation ATS

On July 18, 2018, the Securities and Exchange Commission (SEC or Commission) voted unanimously to adopt significant amendments to Regulation ATS (Reg ATS). The amendments, which impose heightened public disclosure...more

FINRA Requests Comment on Proposed New Outside Business Activities Rule

FINRA is seeking comment on a proposed new rule, FINRA Rule 3290 (the “Proposed Rule”), which governs the outside business activities and private securities transactions of registered persons. The Proposed Rule would replace...more

SEC Confirms Certain ICOs Are Securities Offerings; Regulators Renew Focus on Cryptocurrencies

What Is an ICO? An ICO, or initial coin offering, is the sale of virtual coins or tokens, often as a means of capital raising by startup companies that are involved in blockchain technology. Depending on the terms of the...more

FINRA and the MSRB Issue FAQs on Bond Mark-Up Disclosure

On July 12, 2017, the Financial Industry Regulatory Authority (FINRA) and the Municipal Securities Rulemaking Board (MSRB) published new implementation guidance on the bond mark-up disclosure requirements set to take effect...more

SEC Approves Bond Mark-Up Disclosure Rules

On November 17, 2016, the Securities and Exchange Commission (SEC or Commission) approved new rules requiring dealers to disclose on retail customer confirmations their mark-ups and mark-downs on most municipal and corporate...more

SEC's Equity Market Structure Advisory Committee Considers an Access Fee Pilot and Changes to the Regulation of Trading Venues

On April 26, 2016, the Equity Market Structure Advisory Committee (EMSAC or Committee) held its fourth meeting at the Securities and Exchange Commission (Commission or SEC) in Washington DC. The Committee is considering...more

Registration of Associated Persons with Algorithmic Trading Responsibilities

On April 7, 2016, the Securities and Exchange Commission (“SEC”) approved the Financial Industry Regulatory Authority's (“FINRA”) proposal to amend NASD Rule 1032 (Categories of Representative Registration) to require...more

SEC's Equity Market Structure Advisory Committee Considers Market Volatility and Customer Issues

The Equity Market Structure Advisory Committee (EMSAC or Committee) held its third meeting at the Securities and Exchange Commission (Commission or SEC) in Washington DC on February 2, 2016. The Committee is considering...more

SEC Proposes Significant Regulatory Changes for Alternative Trading Systems

On November 18, 2015, the Securities and Exchange Commission (“SEC” or “Commission”) proposed significant changes to the regulatory requirements applicable to dark pools and other alternative trading systems (“ATSs”) that...more

CFTC Proposes “Regulation AT” for Automated Trading

I. Executive Summary - On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or...more

SEC Approves NMS Plan to Implement Tick Size Pilot for Small Cap Stocks

In June 2014, the Securities and Exchange Commission (“SEC” or “Commission”) issued an order directing the national securities exchanges and the Financial Industry Regulatory Authority (collectively, the “Participants”) to...more

SEC Equity Market Structure Advisory Committee: Assessing Complexity in the U.S. Equity Markets

On May 13, 2015, the Equity Market Structure Advisory Committee (the “EMSAC” or “Committee”) held its inaugural meeting (the “Inaugural Meeting”) at the Securities and Exchange Commission (the “Commission” or “SEC”) in...more

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more

Expanding Oversight of Active, Proprietary Trading Firms: SEC Proposes Amendments to Rule 15b9-1

Overview - On March 25, 2015, the Securities and Exchange Commission ("SEC" or "Commission") proposed an amendment to Rule 15b9-1 (the “Proposal”) under the Securities Exchange Act of 1934 ("Exchange Act") that, if...more

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