Recent SEC staff no-action letter allows certain sub-advisers to avoid the burdensome surprise examination requirement under the Custody Rule.
On April 25, the US Securities and Exchange Commission (SEC) staff provided...more
Based on recent announcements from the SEC and its Staff, changes may be forthcoming for advisers’ use of third-party solicitors for government entity clients....more
7/29/2015
The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts.
On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more
We have prepared this white paper to address errant claims made in the Council of Economic Advisers’ (CEA) report, “The Effects of Conflicted Advice on Retirement Savings” (CEA Report), regarding perceived inadequacies in the...more
Twin reports provide a roadmap to best practices.
U.S. financial markets and participants, much like other segments of the U.S. economy, are prime targets for technological hacks, intrusions, and breaches that can occur...more
Although the MSRB’s new best execution rule is generally consistent with FINRA’s, differences exist and questions remain regarding FINRA’s examination and enforcement of the requirements....more
The respective proposals would require disclosure of price differentials in certain same-day fixed-income transactions that involve retail customers and go beyond existing price differential disclosure requirements in equity...more
On November 19, 2014, the U.S. Securities and Exchange Commission (SEC) unanimously adopted Regulation Systems Compliance and Integrity (Regulation SCI) under the Securities Exchange Act of 1934 (Exchange Act). Regulation SCI...more
SEC Chair Mary Jo White outlined a broad market structure proposal that would require high-frequency traders to register with the SEC as dealers and that could signal the end of the dealer-trader distinction....more
The guidance addresses expense arrangements, buy-in procedures, free credit balances, sweep programs, and bulk transfers, among other things.
On March 6, the staff of the Securities and Exchange Commission (SEC) issued...more
In two separate letters, the SEC staff addresses operational concerns raised by broker-dealers in connection with sweep program authorizations and the use of certain nonaffiliated U.S. branches of foreign banks....more
SEC staff action may head off congressional action to exempt M&A Brokers from registration.
On February 3, the staff of the Securities and Exchange Commission (SEC) issued a no-action letter that permits an M&A broker...more