Jeanne Hammerstrom of Benesch on Longevity, Growth, Execution & Retention as a legal CMO - Passle CMO Series Podcast
Payment for Order Flow (PFOF) and Gamification: Your Questions Answered
The current SEC administration has expressed the view that most crypto assets are offered and sold as securities and has proposed several rules that address “digital asset securities” or “crypto asset securities.” In this...more
While the SEC meddling in industry pricing and other commercial matters is not a new phenomenon, a recent SEC proposal reflects an enhanced willingness by the agency to tightly grip the industry’s purse strings (and a slow...more
On January 9, 2024, the Financial Industry Regulatory Authority published its 2024 FINRA Annual Regulatory Oversight Report. Previously titled Report on FINRA’s Examination and Risk Monitoring Program, the Report is released...more
The proposal would codify for the first time the federal-level best execution standard for brokers and related obligations. New Regulation Best Execution would result in a pivot from what has been a principles-based approach...more
On December 14, 2022, the Securities and Exchange Commission (the SEC or Commission) proposed Regulation Best Execution (Proposed Reg Best Ex), which would establish through Commission rules a federal best execution...more
The US Securities and Exchange Commission (SEC) proposed Regulation Best Execution (Proposal or Proposed Regulation Best Execution) under the Securities and Exchange Act of 1934 (Exchange Act) to enhance the existing...more
On December 14, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard...more
We here at SECond Opinions pride ourselves on staying current on all things SEC. But how about when in a single day, the SEC finalizes one rule and proposes four others (totaling 1,656 pages!) that could drastically change...more
On December 14, 2022, the SEC proposed four separate equity market structure rulemakings, each of which, if adopted, will have significant effects on the markets and various industry participants. While designed to address...more
The SEC Division of Examinations recently published a Risk Alert on quarterly reports required under Exchange Act Rule 606, which are published by broker-dealers to provide customers with insight into factors influencing...more
FINRA recently provided an update on the August 2021 review of its members’ practices and controls related to the opening of options accounts and related areas, including account supervision, communications, and diligence. ...more
At its next open meeting on December 14, 2022, the US Securities and Exchange Commission is expected to propose a series of rules and rule amendments that have the potential to fundamentally reshape the structure of the US...more
The Commission’s rule writing calendar may be about to have a meltdown. The agency is considering a number of significant rule writing-proposals covering important areas. A number of those proposals are controversial,...more
This podcast details why payment for order flow and gamification are in the news, and how regulators and the industry in general are addressing related issues and concerns. The episode features Brattle Senior Consultant...more
On January 9, 2020, FINRA released its 2020 Risk Monitoring and Examination Priorities Letter for its member firms. The exam priorities are organized into four categories: (1) sales practice and supervision; (2) market...more
The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...more
Rewards and Risks in Opportunity Zone Funds - H.R. 1—informally known as the Tax Cuts and Jobs Act—became law on December 22, 2017. Included in the Act is a new program intended to spur the reallocation of investments...more
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS – OCIE Publishes Risk Alert on Compliance Issues Relating to Best Execution – On July 11, 2018, the Office of Compliance Inspections and...more
The U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a National Exam Program Risk Alert on July 11, 2018. The Risk Alert highlights OCIE’s observations of compliance issues...more
On July 11, 2018, the Securities and Exchange Commission (SEC) issued a risk alert outlining certain compliance issues identified by its Office of Compliance Inspections and Examinations (OCIE) related to the obligation to...more
Best execution is currently a hot topic for global regulators and the past year has seen notable regulatory focus in this area. Amid this development, firms are recommended to review their global best execution compliance...more
On April 1, 2017, District Judge John G. Koeltl of the United States District Court for the Southern District of New York dismissed a putative class action against brokerage firm E*TRADE Financial Corporation and E*TRADE...more
The SEC’s apparent preference for administrative proceedings as a venue for its enforcement actions continues to draw criticism. H.R. 3798 is now pending in the House of Representatives. The bill is tilted the “Due Process...more