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Financial Industry Regulatory Authority (FINRA) Regulation S-P

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - July 2024

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Faegre Drinker Biddle & Reath LLP

FINRA to Member Firms: “You Heard the SEC, Create Plans for Data Breaches Now!”

On May 15, 2024, the SEC announced it would make amendments to Regulation S-P (Reg S-P). This will be the first amendment to the regulation since its adoption 24 years ago in 2000. The regulation focuses on how institutions...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - June 2024

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - May 2024 - 2

Securities and Exchange Commission. Customer ID requirements. On May 13, 2024, SEC and FinCEN proposed a rule designed to make it more difficult for criminal actors to establish customer relationships with investment...more

Goodwin

A Closer Look at the SEC’s Cybersecurity Rules for Covered Entities and Market Entities

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The SEC is continuing its campaign to overhaul cybersecurity, cyber incident reporting, and privacy controls and requirements for financial services industry registrants, their service providers, and corporate America...more

Goodwin

SEC to Impose Significant New Privacy and Cybersecurity Rules for BDs, RIAs, TAs, and Mutual Funds

Goodwin on

The SEC continues its overhaul of cybersecurity, cyber incident reporting, and privacy controls and requirements for industry registrants, their services providers, and corporate America generally. On March 15, 2023, the SEC...more

Bressler, Amery & Ross, P.C.

FINRA’s September 2021 Exam Letter

Last week FINRA announced a new inquiry into firms’ use of social media and “influencers” to attract clients. After the well-publicized market volatility in GameStop, which was bolstered by an online influencer known as...more

Morgan Lewis

Outsourcing: FINRA Outlines Onboarding and Supervision Suggestions for Use of Third-Party Vendors

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A recent FINRA regulatory notice recasts existing obligations regarding outsourcing as a procedural roadmap for broker-dealers to “consider” when using third-party vendors. The Financial Industry Regulatory Authority, Inc....more

Bass, Berry & Sims PLC

FINRA Officials Provide Insight on Enforcement, Examination and Rulemaking Priorities Amid COVID-19 Pandemic

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Virtual Meetings - Colby said that consistent with FINRA’s rules requiring in-person hearings, it has conducted no remote hearings. He said there have been a handful of remotely conducted FINRA arbitrations, but those are...more

Mintz - Employment Viewpoints

FINRA Fines Broker-Dealer for Sharing Customer Data with Third-Party Vendor

Kestra Investment Services LLC (“Kestra”) was fined $125,000 by FINRA for sharing personal customer data with a third-party vendor. Kestra had engaged the vendor to assist newly hired brokers with the transfer of customer...more

King & Spalding

Safe and Sound - FINRA and the SEC Issue Guidance on Handling Customer Information and Communications

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Recently, the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) separately issued important guidance regarding customer communications surrounding the...more

Katten Muchin Rosenman LLP

Bridging the Week - April 2019 #3

The watchdog arm of the Securities and Exchange Commission – the Office of Compliance Inspections and Examinations – issued a Risk Alert summarizing breakdowns in compliance by broker-dealers and investment advisers of their...more

Carlton Fields

Cybersecurity Still Top FINRA Operational Risk

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On January 4, the Financial Industry Regulatory Authority (FINRA) published its annual Regulatory and Examination Priorities Letter providing firms with information about areas FINRA plans to review in 2017 as well as...more

Bracewell LLP

FINRA Fines Lincoln Financial Sub $650,000 For Cybersecurity Shortcomings

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A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more

Carlton Fields

FINRA Targets Stockbroker’s Impermissible Transfer of Client Account Information

Carlton Fields on

FINRA recently settled an action against a registered representative of a broker-dealer for alleged violations regarding the safeguarding and use of private consumer data. The broker accepted and consented to the settlement...more

Burr & Forman

FINRA Proposes Rules to Combat Financial Exploitation of Seniors

Burr & Forman on

FINRA Reg. Notice 15-37 (Oct. 2015) requests prompt comment (by November 30) on proposed Rules aimed at detecting and minimizing financial exploitation of seniors and other “vulnerable” adults....more

Morrison & Foerster LLP

Following the Wisdom of the Crowd? A Look at the SEC’s Final Crowdfunding Rules

In this alert, we provide a detailed overview of the final rules, Regulation Crowdfunding, which will be applicable to crowdfunding offerings conducted in reliance on Section 4(a)(6) of the Securities Act of 1933 as amended...more

Morgan Lewis

Proactive Approach To Cybersecurity: Recent SEC guidance and enforcement actions suggest that reactive firms may be in the SEC’s...

Morgan Lewis on

In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more

Katten Muchin Rosenman LLP

Cyber-Attacks: Threats, Regulatory Reaction and Practical Proactive Measures to Help Avoid Risks

I. Cybersecurity; Its Importance and Relevance – How We Got to Where We Are Today - In the past few months, the White House, Home Depot, JP Morgan, Hard Rock Hotels, Tesla, the St. Louis Federal Reserve, the Internal...more

Snell & Wilmer

FINRA Fines Financial Firm for Failing to Encrypt Customer Data on Lost Laptop

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Like other federal agencies exercising regulatory power in the data privacy and security arena, the Financial Industry Regulatory Authority (“FINRA”) is cracking down on firms that fail to meet required data security...more

BakerHostetler

Lost, Unencrypted Laptop Leads FINRA to Fine a Broker-Dealer $225,000 for Violating Reg S-P

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With the recent focus by the SEC and FINRA on cybersecurity for broker-dealers and investment advisers as a backdrop, FINRA recently brought and settled an enforcement action under SEC Regulation S-P against broker-dealer...more

BakerHostetler

Broker-Dealers and Investment Advisers Now Targeted by Both Cyber Intruders and SEC Cybersecurity Examiners

BakerHostetler on

Cybersecurity has increasingly become a critical issue for all types of businesses, few more so than broker-dealers, investment advisers and others in the financial sector. The cyber threat is much broader than customer data...more

Eversheds Sutherland (US) LLP

Cybersecurity Issues in the Financial Services Industry: Fasten your cyber belts, it's going to be a bumpy night

Few topics are as hot as cybersecurity. Recent high-profile data breaches at national retailers have made cybersecurity a frequent topic on Capitol Hill and an issue of growing concern to average Americans. Not surprisingly,...more

Broker-Dealer Compliance + Regulation

Broker-Dealer Cybersecurity: Protect Yourself or Pay the Price

In its recently issued 2014 Regulatory and Examination Priorities Letter, FINRA stated that cybersecurity remains a priority given the ongoing cybersecurity issues reported across the financial services industry, including...more

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