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SEC Finalizes Changes to Dealer Definition – Does Not Exempt Private Funds or Proprietary Trading Firms

At a contentious open meeting on February 6, 2024, the Securities and Exchange Commission (Commission) voted three to two to adopt rule amendments (Final Rules) under the Securities Exchange Act of 1934, as amended (Exchange...more

Artificial Intelligence: Legal and Regulatory Issues for Financial Institutions

Over the last six months, artificial intelligence (AI) has captured the public imagination in a way it never has before. A new generation of AI-powered language models make use of a deep learning architecture known as a...more

SEC Examinations Division Issues Risk Alert Regarding Digital Asset Securities

The staff of the Securities and Exchange Commission’s Division of Examinations (Staff) on February 26, 2021, published a Risk Alert (Risk Alert)1 regarding digital asset securities.2 The Risk Alert highlights observations...more

SEC Staff Issues No-Action Letter Regarding Digital Asset Securities Trading on ATS Platforms

The Staff of the Securities and Exchange Commission’s Division of Trading and Markets (Staff) issued a no-action letter to the Financial Industry Regulatory Authority on September 25, 2020 (Letter), in which the Staff stated...more

SEC and FINRA Staffs Jointly Address Broker-Dealer Custody of Digital Asset Securities

The Staffs of the Securities and Exchange Commission’s Division of Trading and Markets and the Financial Industry Regulatory Authority’s Office of General Counsel (jointly, Staffs) issued a Joint Statement on July 8, 2019...more

SEC Issues Statement on Potentially Unlawful Online Platforms for Trading Digital Assets

The staff of the Divisions of Enforcement and Trading and Markets (collectively, Staff) of the U.S. Securities and Exchange Commission (SEC) on March 7, 2018 jointly issued a statement on digital asset trading platforms...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

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