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FINRA Publishes Metaverse Report and Requests Industry Comments

FINRA’s Office of Financial Innovation published a report on “The Metaverse and the Implications for the Securities Industry” to raise awareness among its member firms and the broader securities industry and seek industry...more

SEC EXAMS Division 2025 Priorities Signal Continued Scrutiny of Broker-Dealers

The SEC Division of Examinations (EXAMS) recently published its list of priorities for 2025, providing a roadmap for broker-dealers and other registrants to better understand where examination teams will focus their efforts...more

SEC Rulemaking Returns After Quiet Stretch: Assessing the SEC “Reg. Flex” Agenda for BDs and Exchanges

Despite the SEC’s already prolific rulemaking under Chair Gensler, the agency still has a few dozen additional rulemaking initiatives in the queue. Broker-dealers, exchanges, and other trading and markets participants can...more

FINRA Proposes Extending the MQP CE Window

On April 30, 2024, FINRA proposed amendments its Maintaining Qualifications Program (“MQP”) to reopen the period in which certain participants can complete their prescribed 2022 and 2023 continuing education (“CE”)...more

SEC to Ban Exchange Volume-Based Pricing Tiers

While the SEC meddling in industry pricing and other commercial matters is not a new phenomenon, a recent SEC proposal reflects an enhanced willingness by the agency to tightly grip the industry’s purse strings (and a slow...more

FINRA Approves Remote Branch Inspection Pilot Program

On January 23, 2024, FINRA announced the addition of new Supplementary Material .18 to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year remote inspections pilot program (Pilot Program) to allow eligible members...more

FINRA (Finally) Adopts Work-From-Home Supervisory Location Category and Requirements

Firms will be able to treat private residences from which certain supervisory activity is conducted as non-branch offices instead of OSJs. The adoption comes after nearly two years of FINRA efforts to align its supervisory...more

SEC Expands Dealer Definition to Capture Large Traders Regularly Providing Liquidity to the Markets

High-frequency traders, private funds, decentralized exchange automated market makers, and even state pension plans should consider whether the expanded dealer definition triggers the need to register as a securities dealer...more

Crypt-D’OH! FINRA says 70% of BD Crypto Asset Communications Are Deficient

In January 2024, FINRA provided an update on its targeted examination of firms’ crypto asset communications. FINRA launched this targeted examination series in November 2022 to “review the practices of certain member firms...more

FINRA Publishes 2024 Annual Regulatory Oversight Report

On January 9, 2024, FINRA published its 2024 Annual Regulatory Oversight Report (the “Report”). FINRA publishes the Report as a way to provide its broker-dealer members with insight into findings from FINRA’s Member...more

FINRA Kicks Off the Holiday Season With a Proposal to Permit the Use of Some Projections and Targeted Returns

FINRA has offered a gift to member firms and fund managers just in time for the holiday season — but like a new puppy, the gift comes with a lot of responsibility. FINRA filed a proposed rule change to amend FINRA Rule 2210...more

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

A Closer Look at the SEC’s Cybersecurity Rules for Covered Entities and Market Entities

The SEC is continuing its campaign to overhaul cybersecurity, cyber incident reporting, and privacy controls and requirements for financial services industry registrants, their service providers, and corporate America...more

SEC Regulatory Agenda Showcases Important Rules by Fall 2023

The federal Office of Information and Regulatory Affairs recently published the SEC’s Spring 2023 “Reg Flex” agenda. Chairman Gary Gensler sets the SEC’s agenda, which identifies rules that the agency expects to consider over...more

FINRA Asks How to Improve Capital Formation Rules; Public Companies and Fund Managers May Have Ideas

In Regulatory Notice 23-09, FINRA provides an update on actions it currently has under way to promote capital formation and the capital-raising process. FINRA also requests comment regarding whether there are other changes to...more

SEC Proposes New Regulation Best Execution - Brokers Must Achieve “Most Favorable Price” for Customers; Heightened Obligations for...

The proposal would codify for the first time the federal-level best execution standard for brokers and related obligations. New Regulation Best Execution would result in a pivot from what has been a principles-based approach...more

SEC Requires T+1 Settlement Cycle

SEC efforts to shorten the US securities settlement cycle come as no surprise, yet these changes will have profound implications for the industry, US and global financial markets, and financial services generally. The push to...more

SEC "Gift" to the Industry: Four Market Structure Proposals, 3-2 Votes (In Part), but No Partridge in a Pear Tree

On December 14, 2022, the SEC proposed four separate equity market structure rulemakings, each of which, if adopted, will have significant effects on the markets and various industry participants. While designed to address...more

SEC Staff Risk Alert Criticizes Broker-Dealer Reports on Best Execution and Payment for Order Flow

The SEC Division of Examinations recently published a Risk Alert on quarterly reports required under Exchange Act Rule 606, which are published by broker-dealers to provide customers with insight into factors influencing...more

FINRA Sheds Light on Path to Digital Asset Security Broker Registration

Interest in engaging in a crypto business seems to be at an all-time high, including doing so in or through regulated and compliant businesses in traditional financial services firms. Brokers-dealers sit atop that list....more

FINRA Exam Targets Broker Crypto Asset Communications

FINRA recently announced targeted exams of its members focused on certain retail communications concerning “crypto asset” products and services between July 1, 2022 and September 30, 2022. For purposes of the exams, FINRA...more

FINRA Urges Firms to Focus on Succession Planning

FINRA recently published Regulatory Notice 22-23, providing guidance regarding firm and representative succession planning, including relevant FINRA rules and administrative processes and questions firms can consider when...more

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