Payment for Order Flow (PFOF) and Gamification: Your Questions Answered
Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion
Investment Management and Private Funds Roundtable – June 2020
Videocast: Asset management regulation in 2020 videocast series – FinTech initiatives
Videocast: Asset management regulation in 2020 videocast series – Fiduciary investment advice: The patchwork emerges
Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
Videocast: Asset management regulation in 2020 videocast series – Complying with new SEC rules for broker-dealers
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Regulation Best Interest Videocast Series: Establishing An Investment Platform Post-Regulation BI
Investment Management Update - Focus on Data Privacy and Cybersecurity
On April 30, 2024, FINRA proposed amendments its Maintaining Qualifications Program (“MQP”) to reopen the period in which certain participants can complete their prescribed 2022 and 2023 continuing education (“CE”)...more
FINRA filed a rule amendment with the SEC on January 2 to propose amending FINRA Rule 3240, Borrowing From or Lending to Customers (SR-FINRA-2024-001). This proposed rule amendment is designed to strengthen the general...more
On November 13, 2023, FINRA filed with the SEC a proposal to amendment to Rule 2210 that would create a tailored exception from the general prohibition on projections in marketing materials and other communications with...more
I. INTRODUCTION AND OVERVIEW - Gary Gensler’s tenure-to-date as Chairman of the Securities and Exchange Commission (“SEC”) is striking for its exceptionally active rulemaking agenda. Two rulemakings of tremendous import to...more
In April 2023, the SEC re-proposed amendments to Exchange Act Rule 3b-16 to expand the definition of what it means to be an exchange. When the SEC initially proposed these amendments in January 2022, there were zero direct...more
Firms would be able to treat private residences as non-branch offices instead of OSJs under certain circumstances. FINRA hopes to align its supervisory rules with current work-from-home practices....more
FINRA recently filed a proposed rule change with the SEC to yet again delay the implementation date to October 25, 2023, for amendments to Rule 4210 (Margin Requirements) for Covered Agency Transactions....more
The Securities and Exchange Commission (SEC) recently adopted substantial amendments to shareholder reports used by investment companies, including mutual funds and exchange-traded funds (ETFs) (collectively, funds)...more
REGULATORY UPDATES - SEC Announces Leadership Changes - Anthony (“Tony”) C. Thompson was appointed to a second term as a board member of the Public Company Accounting Oversight Board (“PCAOB”), which will run until...more
FINRA recently proposed amendments to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year pilot program (Pilot Program) to allow member firms to conduct remote branch office inspections. In a nod to where...more
Back in April 2022, we wrote about the SEC killing the Dealer/Trader distinction. We also noted then that it would come as no surprise to see the SEC re-propose amendments to Exchange Act Rule 15b9-1. Just a few months later,...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) is urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption; the Financial Industry Regulatory Authority...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
As it was for the rest of the world, 2021 was an interesting year for the Financial Industry Regulatory Authority (FINRA). Originally published in American Bar Association’s Securities Litigation section - March 17th,...more
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
While the US Securities and Exchange Commission seeks to modernize electronic recordkeeping requirements in a technology-neutral manner, its proposed amendments are unclear as to the permissible use of the “cloud” or...more
The US Securities and Exchange Commission (SEC) published for comment on September 30 a proposed rule change by the Financial Industry Regulatory Authority (FINRA) that would amend FINRA Rule 2231—the customer account...more
FINRA filed a proposed rule change with the US Securities and Exchange Commission (SEC) on August 26, 2021 to delay the effective date of changes to FINRA Rule 4210 that were previously implemented on December 15, 2016. The...more
On Friday, May 7, 2021, the Financial Industry Regulatory Authority (FINRA) filed a proposal with the Securities and Exchange Commission (SEC) to amend the provisions of a yet-to-become effective version of FINRA Rule 4210...more
The proposed amendments could significantly alter the landscape for extended settlement of securities offerings by expressly limiting the public offering exception for “when-issued” securities to equity IPOs. Key Points: ...more
In setting forth its rationale, FINRA observed that private placement retail communications reviewed by AdReg have “revealed significant and pervasive” violations of FINRA Rule 2210. On October 28, 2020, the Financial...more
Thwarting the financial exploitation of seniors and other vulnerable investors has been an increasing focus of several financial regulators in recent years, including the Financial Industry Regulatory Authority (“FINRA”). In...more
On Wednesday, August 26, 2020, the Securities and Exchange Commission (the “SEC”) changed the investment landscape as we know it by modestly relaxing the eligibility rules for investment in private offerings. The Adopting...more
The Financial Industry Regulatory Authority, Inc. filed proposed amendments with the Securities and Exchange Commission on March 19, 2020, to FINRA Rule 2111 (Suitability Rule) and Capital Acquisition Broker (CAB) Rule 211...more
On December 18, 2019, the SEC proposed to amend its definition of “Accredited Investor” with hopes to expand access to private capital markets to a wider range of investors. The proposed changes create two new categories of...more