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Some Good News for the Loan Industry—Loans Are Not Securities

Although the loan industry has long looked at loans as being obligations that arise in a commercial lending relationship, which are therefore not securities under Federal and state securities laws, the law supporting this...more

FINRA Issues 2020 Examination Priorities

The Financial Industry Regulatory Authority published its 2020 Risk Monitoring and Examination Priorities Letter (Priorities Letter) on January 9, 2020. The Priorities Letter identifies four core areas on which FINRA will...more

FINRA Issues FAQs on Rules Relating to Financial Exploitation of Seniors and Other Vulnerable Adults

The Financial Industry Regulatory Authority (FINRA) has published frequently asked questions (FAQs) for complying with new FINRA Rule 2165 (Financial Exploitation of Specified Adults) and amendments to FINRA Rule 4512...more

FINRA Seeks Comments on its Engagement Programs

The Financial Industry Regulatory Authority (FINRA), on March 21, 2017, published a Special Notice soliciting comments on various existing FINRA engagement programs (Notice). This request for comment is one component of...more

SEC Fines Broker-Dealer for Inadequate Information Barriers

The U.S. Securities and Exchange Commission (SEC) on February 13, 2017, issued a cease and desist order (Order) and imposed a $100,000 civil penalty against broker-dealer Sidoti & Company, LLC (Broker-Dealer), to settle...more

SEC Charges Private Equity Adviser for Unregistered Brokerage Activity

The U.S. Securities and Exchange Commission (SEC) on June 1, 2016 announced a settled enforcement action against a private equity fund manager (Adviser) for acting as a broker-dealer without registering. The case is...more

Effect of Recent New York City Amendments May Limit Brokers and Advisers in Conducting Credit and Background Checks on Potential...

The New York City Council recently passed two amendments to the New York City Human Rights Law that are likely to substantially affect the manner in which firms in New York City may evaluate the qualifications and background...more

Recent SEC Actions Focus on Broker-Dealer Activity of Private Funds, Highlight Perils, and Generate Controversy

A recent public statement by a member of the senior staff (“Staff”) of the Securities and Exchange Commission (“SEC”) and recent SEC enforcement actions have reminded private equity and other private fund managers (such as...more

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