On June 18, 2019, the U.S. Court of Appeals for the District of Columbia Circuit (the court) dismissed a challenge to Financial Industry Regulatory Authority (FINRA) pay-to-play Rule 2030 (the rule) brought by the New York...more
6/28/2019
/ Administrative Authority ,
Arbitrary and Capricious ,
Campaign Contributions ,
Corruption ,
Dismissals ,
Federal Contractors ,
Federal Election Campaign Act ,
Financial Industry Regulatory Authority (FINRA) ,
First Amendment ,
Government Entities ,
Important Governmental Objectives ,
Investment Adviser ,
Pay-To-Play ,
Political Contributions ,
Political Parties ,
Preemption ,
Securities and Exchange Commission (SEC) ,
Solicitation ,
Standing
Financial institutions and their employees may be subject to the following federal pay-to-play rules: SEC Rule 206(4)-5 for investment advisers; CFTC Rule 23.451 for commodities-backed swap dealers; FINRA Rule 2030 for...more
5/2/2019
/ Broker-Dealer ,
CFTC ,
Commodities-Backed Swap ,
De Minimus Doctrine ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Investment Adviser ,
MSRB ,
Municipal Advisers ,
Pay-To-Play ,
Political Contributions ,
Securities and Exchange Commission (SEC) ,
Swap Dealers
Recently, the Municipal Securities Rulemaking Board (MSRB) noted in its quarterly compliance newsletter dated June 8, 2018 that it has “compliance concerns” regarding issuer-solicited charitable donations. The MSRB’s...more
On October 24, 2016, the Financial Industry Regulatory Authority (FINRA) announced in Regulatory Notice 16-40 that its pay-to-play and related recordkeeping rules, FINRA Rules 2030 and 4580, will take effect on August 20,...more
The Financial Industry Regulatory Authority (FINRA) has filed a regulatory notice seeking comment on proposed changes to its gift, business entertainment and noncash compensation rules for broker-dealers. Comments must be...more
This week, on Thursday, August 25, 2016, the SEC approved FINRA Proposed Rules 2030 and 4580 (the Proposed Rules) as they had been proposed by FINRA. The Proposed Rules would impose pay-to-play restrictions and recordkeeping...more
On June 21, 2016, the Financial Industry Regulatory Authority extended the time for the Securities and Exchange Commission (SEC) to act on Proposed Rules 2030 and 4580 (the Proposed Rules) to August 26, 2016. The Proposed...more
On March 29, 2016, the Securities and Exchange Commission (SEC) filed an order instituting proceedings (the Order) intended to determine whether to approve or disapprove Financial Industry Regulatory Authority (FINRA)...more
On February 17, 2016, the Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2016-06 that its draft amendments to Rule G-37 on political contributions, and related amendments to Rules G-8 and G-9 on...more
On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) submitted Rules 2030 and 4580 (the Draft Rules) to the Securities and Exchange Commission (SEC) for approval. The Draft Rules set forth pay-to-play...more
On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) and Municipal Securities Rulemaking Board (MSRB) submitted their respective pay-to-play rules to the Securities and Exchange Commission (SEC) for...more
SEC Municipal Advisor Examination Initiative -
The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently updated the National Association of Municipal Advisors on...more
Proposed Amendments to MSRB Rule G-20 -
On September 2, 2015, the MSRB filed with the Securities and Exchange Commission (SEC) proposed amendments to Rule G-20, with conforming changes to related recordkeeping Rules G-8...more
On June 25, 2015, the Securities and Exchange Commission (SEC) issued Release No. IA-4129 setting July 31, 2015, as the compliance date for SEC Rule 206(4)-5's placement agent restrictions on using third-party and affiliated...more
On August 19, 2014, the Securities and Exchange Commission (SEC) announced that its Office of Compliance Inspections and Examinations (OCIE) will begin a two-year examination initiative (the initiative) through the National...more