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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

NASAA (State Securities, not Outer Space) Cautions Investors Exploring Opportunities in the Metaverse

​​​​​​​The North American Securities Administrators Association (NASAA), an organization of state and provincial securities regulators in the United States, Canada, and Mexico, recently issued an investor advisory warning...more

BD and IA Conflicts of Interest: SEC Staff Says Don’t Set It (Them) and Forget It (Them)

​​​​​​​SEC staff recently served up a juicy staff bulletin covering the standards of conduct for broker-dealer and investment adviser conflicts of interest. The staff bulletin includes 13 Q&As categorized into five different...more

FINRA Reminds Firms of Evolving Definition of “Prompt” Order Execution

FINRA recently reminded firms of their obligation to execute marketable customer orders fully and promptly. While this seems fairly routine, what’s notable about the reminder is that “prompt” doesn’t necessarily mean what it...more

SEC Proposes Securities Lending Transaction Reporting Requirements

On November 18, 2021, the U.S. Securities and Exchange Commission proposed new Rule 10c-1, which, if adopted, would create a new reporting and disclosure framework for the securities lending market. Rule 10c-1 would require...more

U.S. Securities and Exchange Commission Division of Examinations Publishes Observations from its Registered Investment Company...

The staff of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) recently published a risk alert spotlighting observations from its “RIC Initiatives” — 200+ examinations of mutual...more

SEC Staff Issues Report on “Meme” Stock Events and Market Structure Considerations

The onset of fall signals a sad realization that summer has ended, but also the joy that “market structure” season has arrived for securities industry participants and policy wonks. Right on cue, in early October, SEC staff...more

SEC Seeks Input on BD and RIA Digital Engagement Practices

The SEC recently solicited public comment on digital engagement practices (DEPs) used by some broker-dealers and investment advisers, including predictive data analytics, differential marketing, and behavioral prompts (such...more

FINRA Adds Continuing Membership Application Requirement to Address Brokers With a History of Misconduct

FINRA recently amended its rules in order to strengthen its tools to respond to brokers with a significant history of misconduct and the firms that employ them. The amended rules include FINRA’s Disciplinary Proceedings...more

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