Hillel Cohn

Hillel Cohn

Morrison & Foerster LLP

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Referral Fees and Commission Sharing - When May Broker-Dealers Share Their Fees with Non-Brokers?

FINRA recently filed proposed rule changes with the SEC addressing when broker-dealers may pay referral fees or otherwise share compensation with persons who are not registered as broker-dealers. The proposed rule changes are...more

10/17/2014 - Broker-Dealer Fee-Sharing FINRA Proposed Regulation Referral Fees SEC Securities Exchange Act

FINRA Invites Public Comment on a Modified Regulatory Scheme for Broker-Dealers Specializing in M&A and Corporate Finance

FINRA is seeking public comment on a much needed overhaul of the regulatory requirements for broker-dealers who specialize in M&A and corporate finance. The overhaul would be accomplished by creating a new category of...more

3/25/2014 - Broker-Dealer FINRA

Private Company M&A Brokers Don’t Need to Register With the SEC as Broker-Dealers

On January 31, 2014, the SEC issued a ground-breaking no-action letter, taking the position that a financial intermediary that limits its business activity to advising privately held companies in M&A transactions need not...more

2/7/2014 - Broker-Dealer No-Action Letters Registration SEC

The Volcker Rule Prohibition on Proprietary Trading: Considerations for Broker-Dealer Affiliates of Foreign Banking Organizations

The Volcker Rule imposes significant restrictions on “proprietary trading” by banking organizations and their affiliates. The purpose of this Memorandum is to discuss how these restrictions may impact broker-dealer affiliates...more

1/10/2014 - Banks Broker-Dealer Foreign Affiliates Foreign Banks Proprietary Trading Volcker Rule

The Impact of the SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Broker-Dealers and Investment...

The SEC recently finalized amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act relaxing prohibitions against general solicitation in certain private offerings of securities implementing Section...more

9/12/2013 - Bad Actors Broker-Dealer Dodd-Frank FINRA General Solicitation Investment Adviser JOBS Act SEC

Chipping Away at Barriers to Global Financial Services: SEC Staff Addresses Issues for Foreign Broker-Dealers under Rule 15a-6

Noting the increasingly global nature of financial markets, the U.S. Securities and Exchange Commission (“SEC”) adopted Rule 15a-6 nearly twenty four years ago to facilitate limited access by foreign broker-dealers to...more

3/29/2013 - Broker-Dealer Rule 15a-6 SEC

One Step Closer to a Fiduciary Duty for Broker-Dealers?

More than two years after an SEC Staff study recommended adoption of a uniform fiduciary standard for broker-dealers and investment advisers, the SEC has taken its first significant step towards possible implementation of the...more

3/7/2013 - Broker-Dealer Dodd-Frank Fiduciary Duty Investment Adviser SEC

FINRA Provides Early Guidance About Its Exam Priorities; Firms Should Take Notice

In its annual summary of regulatory and examination priorities, the Financial Industry Regulatory Authority (FINRA) signaled that it will aggressively pursue market misconduct. The January 11, 2013 report follows closely on...more

1/16/2013 - Broker-Dealer Compliance Cybersecurity FINRA Investment Adviser Investors

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