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Policies and Procedures Investment Firms

SEC Compliance Consultants, Inc. (SEC³)

SEC Tells Advisers What Not to Do in Advertisements

SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more

SEC Compliance Consultants, Inc. (SEC³)

Write the Best Annual Compliance Review Ever!

Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more

Faegre Drinker Biddle & Reath LLP

Hiring Social Media Influencers? How You Influence Matters

FINRA, as part of its targeted exam of member firms’ social media practices for gaining new customers, recently announced an $850,000 fine against M1 Finance LLC (“M1 Finance”) stemming from promotional social media posts...more

K&L Gates LLP

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

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Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

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In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

Goodwin

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

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There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more

Lowenstein Sandler LLP

Recent Developments in FINRA’s Award of Credit for Extraordinary Cooperation Offers Guidance to Member Firms

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In 2020, the Financial Industry Regulatory Authority Inc. (FINRA) settled alleged rule violations with various large investment firms, including Merrill Lynch, Citigroup Global Markets Inc. (CGMI), Transamerica Financial...more

NAVEX

3 Coronavirus Compliance Tips From the SEC

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The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times. So when the Securities and...more

UB Greensfelder LLP

When It Comes To Sanctions, What Does “Relevant Disciplinary History” Mean To FINRA, And Does It Vary Depending On The Size Of The...

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The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a...more

Eversheds Sutherland (US) LLP

Videocast: Form CRS delivery obligations

Beginning June 2020, the SEC will require most broker-dealers and investment advisers to file and deliver a Form CRS to new, prospective and existing customers and clients. As firms begin to prepare Form CRS, much attention...more

Seyfarth Shaw LLP

FINRA Issues Guidance on the Handling of Customers When a Broker Leaves a Firm

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The Financial Industry Regulatory Authority (FINRA) recently issued some expectations/guidance to industry members on FINRA’s expectations when a broker leaves for another firm....more

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