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Broker-Dealer Transparency

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - March 2024 - 2

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Harris Beach PLLC

SEC Examination Priorities for 2024

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The United States Securities and Exchange Commission’s Division of Examinations announced its examination priorities for fiscal year 2024 on October 16, 2023. The timing of the announcement is significant because it is the...more

Jackson Walker

SEC Adopts Sweeping New Private Fund Adviser Rules

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On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”), by a party-line vote of 3-2, adopted new rules applicable to investment advisers to private funds (“Private Fund Advisers”) that address transparency,...more

Zuckerman Spaeder LLP

SEC Adopts New Rules for Private Funds: What Advisers and Investors Need to Know

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On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC” or “Commission”) finalized new rules and amendments under the Investment Advisers Act of 1940 (“Advisers Act”) to enhance the regulation of private fund...more

ArentFox Schiff

NYAG Proposition of Digital Assets Legislation

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On May 5, 2023, New York Attorney General Letitia James announced a landmark bill — the Crypto Regulation, Protection, Transparency, and Oversight (CRPTO) Act — that, if passed, would dramatically tighten regulation on...more

Dorsey & Whitney LLP

Injecting Transparency & Competition into Equity Markets

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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

Rumberger | Kirk

Are Broker-Dealers Acting in the Best Interests of Their Customers? ‘Not Yet,’ Says FINRA

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Noting Deficiencies, FINRA Suggests Best Practices for Reg BI Compliance - During its first-ever review of compliance with Regulation Best Interest (Reg BI), the Financial Industry Regulatory Authority (FINRA) found...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Short Sale Disclosure Rules

On February 25, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it unanimously voted to approve proposed changes requiring certain institutional investment managers (managers) to report short...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes New Rules Aimed at Increasing Short Sale Transparency

On Feb. 25, 2022, the Securities and Exchange Commission (SEC) proposed several new rules with the goal of increasing transparency around short selling. Rule 13f-2 would require institutional investment managers (Managers)...more

Holland & Knight LLP

New SEC Enforcement Actions Bring Number of Firms Charged with Form CRS Failures to 42

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The SEC's Division of Enforcement continues to focus on registrants' compliance with Form CRS, a byproduct of the agency's rulemakings "designed to enhance the quality and transparency of retail investors' relationships with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2021

In this issue, we cover regulatory developments impacting the investment management sector, including updates on activism activity during the 2021 proxy season, as well as the status of multiple SEC and NYSE proposals,...more

Mayer Brown Free Writings + Perspectives

SEC Amends Rule 15c2-11

On September 16, 2020, the Securities and Exchange Commission adopted amendments to Exchange Act Rule 15c2-11.  This rule was last amended about thirty years ago.  Rule 15c2-11 prescribes requirements relating to the...more

Goodwin

Financial Services Weekly Roundup: OCC Finalizes New CRA Rule; Regulators Continue To Provide COVID-19-related Relief

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In This Issue. The Office of the Comptroller of the Currency (OCC) finalized a rule to strengthen and modernize regulations under the Community Reinvestment Act; the Securities and Exchange Commission (SEC) voted to adopt...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Troutman Pepper

Investment Management Update - October 2019

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SEC Adopts ETF Rule - On September 25, 2019, the Securities and Exchange Commission (SEC) unanimously adopted Rule 6c-11 under the 1940 Act to modernize the regulation of exchange-traded funds by establishing a clear and...more

UB Greensfelder LLP

“The Opinions Offered Today Are Mine Alone And Do Not Represent The Commission” — A Summary Of Recent Remarks From SEC And CFTC...

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Anyone who has sat through a talk by financial regulators is undoubtedly familiar with the refrain from the individuals that they do not speak for the Commission and that the opinions offered are their own. Even with that...more

Dechert LLP

ESMA Consults on UCITS Performance Fees – Key Considerations for Irish UCITS

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ESMA published a consultation (the “Consultation”) on draft guidelines for UCITS performance fees (the “Draft Guidelines”) on the 16 July 2019. The objective of the Consultation is to obtain stakeholder feedback on the...more

UB Greensfelder LLP

The Disturbingly Cozy Relationship Between FINRA And PIABA

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What exists at the point where PIABA’s transparent self-interest in getting paid and FINRA’s historical lack of transparency about who is actually driving its agenda regarding arbitrations? This: a late December decision by...more

Dechert LLP

Market Participants to Their Corners: Competing Views on Market Data Are on Full Display at the SEC’s Market Data Roundtable

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The Securities and Exchange Commission has solicited the views of exchanges, broker-dealers and investors on a range of questions related to market data since at least 1999 when it published SEC Concept Release: Regulation of...more

Goodwin

SEC Proposal to Enhance Protections and Preserve Choice for Retail Investors in Their Relationships With Investment Professionals

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On April 18, 2018, the Securities and Exchange Commission (SEC) voted to propose a package of rulemakings and interpretations designed, in the words of the accompanying press release, “to enhance the quality and transparency...more

Dechert LLP

FINRA Seeks Comments on its Engagement Programs

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The Financial Industry Regulatory Authority (FINRA), on March 21, 2017, published a Special Notice soliciting comments on various existing FINRA engagement programs (Notice). This request for comment is one component of...more

WilmerHale

Regulators Implement Enhanced Oversight and Propose Transparency for the Treasury Market

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On October 24, 2016, the Federal Reserve Bank of New York (FRBNY) held a conference on “The Evolving Structure of the US Treasury Market” (Conference). The Conference was a sequel to the first annual such event where...more

Goodwin

Financial Services Weekly News - September 2016 #2

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Editor's Note - In this edition. The NYDFS proposed a cybersecurity regulation governing New York-chartered banks and insurance companies, the OCC released its bank supervision priorities in its annual supervision...more

Morgan Lewis

FinCEN Requires Financial Institutions to Obtain Beneficial Ownership

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FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more

Proskauer - Corporate Defense and Disputes

SEC Examination Priorities in 2015 to Focus on Transparency Issues and the Early Detection of Potential Fraudulent or Other...

On January 13, 2015, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2015 examination priorities for investment advisers, broker-dealers and transfer agents. These priorities emphasize the...more

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