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From 1 August 2024, the UK changed its rules on how payments are made for investment research. UK firms may now use bundled payments for third-party research and trading commissions, subject to certain requirements being...more
In our previous alert, Paying for Buy-Side Investment Research: Will the FCA’s Third Way Ease the US-UK Divide?, we discussed the consultation issued by the Financial Conduct Authority (FCA) on proposed rules on payment...more
The UK Financial Conduct Authority (FCA) is planning to lift its ban on asset managers making joint or ‘bundled’ payments to broker-dealers for third-party investment research and execution services. The change is being...more
The issue of how firms should pay for investment research continues to be a controversial topic in the financial markets. The U.S. has maintained the approach it adopted before the mid-2000s, which is to permit investment...more
The U.K. Investment Research Review call for evidence was published on April 3, 2023. Relevant background to these issues is set out in our recent client note, “MiFID II: An Update on the Rules for Unbundling of Research,” in...more
The U.K. Financial Conduct Authority has published a consultation paper on proposed guidance on the regulatory perimeter for multilateral trading facilities and on possible future changes to smaller trading venues' regulatory...more
Cboe Withdraws and Then Submits a Proposed Rulemaking for a Bitcoin ETF - On January 22, 2019, Cboe BZX Exchange (Cboe) withdrew its proposed rulemaking with the U.S. Securities and Exchange Commission (SEC). Had the...more
BROKER-DEALER - FINRA Seeks Comment on Fintech Innovation in Broker-Dealer Industry - On July 30, the Financial Industry Regulatory Authority (FINRA) issued a Special Notice requesting comment on how to continue to...more
BROKER-DEALER - FINRA Seeks Comment on Rule Proposal Regarding High-Risk Brokers - On May 30, the Financial Industry Regulatory Authority published Regulatory Notice 18-16, which seeks comment on proposed rule...more
On April 18, 2018, the U.S. Securities and Exchange Commission (“SEC”) took the long-awaited step of proposing rules, interpretations and guidance (the “Proposed Rules”) that would seek to enhance and clarify the standards of...more
BROKER-DEALER - Nasdaq Has Proposed a New Rule Change To Modify Its System of Volume-Based Credits - The Nasdaq Stock Market LLC (Nasdaq) has filed with the Securities and Exchange Commission a proposed rule change to...more
A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s approach to authorisation; action taken on closet tracking funds; proposed EU...more
This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with the Securities and Exchange Commission (the “SEC”) or with a particular...more
SEC/CORPORATE - SEC Approves NYSE Rule to Facilitate Listing Without an IPO - On February 2, the Securities and Exchange Commissions approved a New York Stock Exchange (NYSE) rule change that facilitates the listing...more
3 November - The Financial Conduct Authority (FCA) published an alert setting out key considerations for principals who have appointed representatives or introducer appointed representatives. Among other things, the alert...more
BROKER-DEALER - FINRA Releases New Targeted Exam Letter Regarding Order Routing Conflicts - On November 10, the Financial Industry Regulatory Authority released the contents of a new Order Routing Conflicts targeted...more
3 October - The Prudential Regulator Authority (PRA) published a policy statement on strengthening accountability in banking and changes to senior managers regime (SMR) forms. The changes to the SMR forms will become live on...more
A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details on SEC’s no action letters and Commission’s FAQs on “hard dollar” research payments under...more
The MiFID II regime will have ramifications for buy-side global asset managers and sell-side research providers relating to use of dealing commissions and cost allocation for research expenditures....more
CME Group Reminds Members of Regulatory Requirements for EFRPs and Block Trades Through Disciplinary Actions: The CME Group brought and resolved multiple disciplinary actions against various members and non-members related to...more