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Securities Exchange Act Policies and Procedures Investment Adviser

The Securities Exchance Act is a United States federal statute enacted in 1934 to govern the secondary securities trading market. In addition, the Securities Exchange Act established the Securities and Exchange... more +
The Securities Exchance Act is a United States federal statute enacted in 1934 to govern the secondary securities trading market. In addition, the Securities Exchange Act established the Securities and Exchange Commission (SEC), which is the primary regulatory agency enforcing federal securities laws. less -
BCLP

Regulators Impose Extraordinary Fine Amounts in Recent Off-Channel Communications Enforcement Actions

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The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more

BCLP

SEC Division of Examinations Publishes 2024 Examination Priorities

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On October 16, 2023, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual Examination Priorities for 2024 (the “Exam Priorities”). Consistent with the...more

Seward & Kissel LLP

SEC Enforcement of Off-Channel Communications Continues - New Series of Firms Charged with Penalties Totaling $289 Million

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Summary of the Recent SEC Actions - On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

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On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

Goodwin

SEC Proposes New Regulation Best Execution - Brokers Must Achieve “Most Favorable Price” for Customers; Heightened Obligations for...

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The proposal would codify for the first time the federal-level best execution standard for brokers and related obligations. New Regulation Best Execution would result in a pivot from what has been a principles-based approach...more

Dorsey & Whitney LLP

Avoiding that Subpoena: Large Trends; Mini-Trends

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Tracking the key areas of concern to SEC enforcement can be beneficial for issuers, investment advisers and others that may be subject to scrutiny by the Commission. For example, identifying key areas of focus by determining...more

BCLP

In Finding a Failure to Reasonably Supervise, SEC Highlights Responsibilities of Firms to Create Clear, Written Investigatory...

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A recent Securities and Exchange Commission (“SEC”) order imposed sanctions on a financial institution for failing to reasonably supervise a representative’s conduct. In its findings, the SEC highlights the institution’s...more

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