Clifford E. Kirsch

Clifford E. Kirsch

Sutherland Asbill & Brennan LLP

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FinCEN Customer Due Diligence Rule Proposal

On July 30, 2014, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules (the “Proposed Rules”) to clarify and strengthen customer due diligence requirements for banks, securities...more

8/20/2014 - Banks Broker-Dealer Commodity Pool Due Diligence FCMs Financial Regulatory Reform FinCEN Mutual Funds

M&A Brokers Exempt from SEC Broker-Dealer Registration Requirements

On January 31, 2014, the U.S. Securities and Exchange Commission’s (SEC) Division of Trading and Markets issued a No-Action Letter (Letter)1 that allows a private business broker (M&A Broker) to receive transaction-based...more

2/10/2014 - Broker-Dealer No-Action Letters Registration SEC Securities Exchange Act

SEC and FINRA Publish 2014 Examination Priorities for Broker-Dealers

On January 9, 2014, the U.S. Securities and Exchange Commission (SEC) published its 2014 examination priorities (SEC Letter), just one week after the Financial Industry Regulatory Authority (FINRA) published its 2014...more

1/20/2014 - Broker-Dealer FINRA SEC

FINRA Reverses Course and Issues Guidance Changing Its Interpretation Regarding the Key Issues of "Potential Investors" and...

Background - FINRA’s new suitability requirement, Rule 2011, went into effect July 9, 2012. Because the rule was such a departure from prior standards, FINRA issued Regulatory Notice 12-25 (May 2012) to explain the rule...more

12/19/2012 - Broker-Dealer FINRA Investment Adviser Suitability Rule

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