The first 10 years of the U.S. Securities and Exchange Commission's Rule 15c3-5, known as the market access rule, have been a textbook example of the principle of regulation by enforcement, resulting in an informal patchwork...more
In response to COVID-19, US companies have been forced to make major changes to their businesses in a short period of time. Demand has collapsed; supply chains have been disrupted; and transactions have been put off....more
On August 23, 2019, the Securities and Exchange Commission (SEC or Commission) held in In re John M.E. Saad that the US Supreme Court’s decision in Kokesh v. SEC had no impact on the Financial Industry Regulatory Authority’s...more
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
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
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