James Van De Graaff

James Van De Graaff

Katten Muchin Rosenman LLP

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FINRA’s NAC Strengthens Sanction Guidelines Related to Fraud and Suitability

On May 12, the Financial Industry Regulatory Authority announced that the National Adjudicatory Council (NAC) revised its Sanction Guidelines to call for tougher sanctions against those who commit fraud or make unsuitable...more

5/19/2015 - FINRA Fraud Misrepresentation Omissions Sanctions Suitability Requirements

Proposed Amendments to SEC Rule 15b9-1 Would Require Most Proprietary Trading Broker-Dealers to Become FINRA Members

Consistent with the increased regulatory scrutiny of proprietary trading firms-and high frequency trading firms in particular—the Securities and Exchange Commission (SEC) recently proposed amendments to SEC Rule 15b9-1 (also...more

4/21/2015 - Broker-Dealer FINRA Proposed Amendments Proprietary Trading Rule 15B9-1 SEC Securities Exchange Act

SEC Proposes to Amend Rule 15b9-1

The Securities and Exchange Commission is proposing to amend Rule 15b9-1 under the Securities Exchange Act of 1934, as amended, to require broker-dealers that engage in off-exchange proprietary trading to become members of a...more

4/1/2015 - Broker-Dealer FINRA High Frequency Trading Proposed Amendments Registration Requirement Rule 15B9-1 SEC Securities Exchange Act

FINRA Issues Guidance on Effective Supervision for Firms Engaging in Algorithmic Trading Strategies

The Financial Industry Regulatory Authority released Regulatory Notice 15-09 to provide guidance to member firms and market participants on effective supervision and control practices with respect to algorithmic trading...more

3/31/2015 - Algorithmic Trading FINRA Market Participants SEC Supervision

FINRA Issues Notice on New Rules and Amendments Relating to Transaction-Based Compensation, Membership and Sanctions

The Financial Industry Regulatory Authority released Regulatory Notice 15-07 to alert member firms of the new consolidated rules regarding payments to unregistered persons and membership. The notice also alerts member firms...more

3/31/2015 - FINRA Members New Regulations

Corporate & Financial Weekly Digest - Volume X, Issue 12

In this issue: - SEC Adopts Final Rules for Regulation A+ Offerings - FINRA Issues Notice on New Rules and Amendments Relating to Transaction-Based Compensation, Membership and Sanctions - FINRA Issues...more

3/30/2015 - AIFMD Algorithmic Trading CFTC Final Rules FINRA New Guidance Pharmaceutical Manufacturers Regulation A Regulation SHO SEC Securities Fraud Supervision

FINRA Seeks Comment on Proposal Requiring Registration of Associated Persons Who Develop Algorithmic Trading Strategies

Introduction - As part of its ongoing market structure initiatives related to, among other things, automated trading activities, the Financial Industry Regulatory Authority (FINRA) has issued a proposal that would...more

3/27/2015 - Algorithmic Trading Associated Persons Comment Period FINRA Registration Requirement

FINRA Issues Notice on Background Checks for Registration Applicants

The Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 15-05 to remind member firms of the new consolidated rules on mandatory background checks for individual registration. As first reported in the...more

3/24/2015 - Background Checks FINRA Registration Requirement Regulatory Standards

SEC and FINRA Issue Cybersecurity Publications

On February 3, the Securities and Exchange Commission and Financial Industry Regulatory Authority issued separate publications on cybersecurity risk. The SEC’s risk alert provides summary observations from the SEC’s Office of...more

2/12/2015 - Broker-Dealer Cybersecurity FINRA Industry Examinations Investment Adviser Risk Alert SEC

Corporate and Financial Weekly Digest - Volume X, Issue 5

In this issue: - SEC Advisory Committee on Small and Emerging Companies to Discuss “Accredited Investor” Definition - Glass Lewis Enhances its Pay-for-Performance and Equity Plan Models - SEC Issues New...more

2/9/2015 - Accredited Investors CBOE Cybersecurity Emerging Growth Companies Enforcement Actions Equity Plans ESMA Exchange Offer Federal Reserve FINRA Glass Lewis Pay-for-Performance Ponzi Scheme Private Student Loans Proposed Amendments SEC Small Business Tender Offers

SEC Comments on FINRA’s Proposed Rule Amendment to Increase Pricing Disclosure

On January 20, the Securities and Exchange Commission commented on the Financial Industry Regulatory Authority’s proposed amendment to FINRA Rule 2232 regarding transparency on prices in certain retail transactions in...more

1/27/2015 - FINRA Fixed Income Investments Proposed Amendments SEC

Corporate and Financial Weekly Digest - Volume X, Issue 3

In this issue: - SEC Chair Directs Staff to Review Commission Rule Excluding Conflicting Proxy Proposals - SEC Comments on FINRA's Proposed Rule Amendment to Increase Pricing Disclosure - CFTC Grants...more

1/26/2015 - Broker-Dealer Canada CFTC Class Action Conflicts of Interest ESMA FINRA Forex Hart-Scott-Rodino Act Hong Kong Layering Mary Jo White Mexico Mining Mortgages NFA OCC Proposed Regulation Proxy Access Rule PSLRA Scienter SEC Securities Shareholder Proposals Threshhold Requirements Whole Foods

SEC Approves Amendments to NASD Rule 2340 and FINRA Rule 2310 to Address Values of Direct Participation Program and Unlisted Real...

The Financial Industry Regulatory Authority has issued Regulatory Notice 15-02 regarding the Securities and Exchange Commission’s approved amendments to National Association of Securities Dealers (NASD) Rule 2340 (and...more

1/13/2015 - Amended Regulation FINRA Nasdaq REITS SEC Stocks Valuation

SEC Approves FINRA Rule Proposal Regarding Responsibilities of FINRA Member Firms to Investigate Applicants for Registration

The Securities and Exchange Commission has granted accelerated approval of a Financial Industry Regulatory Authority proposal to adopt FINRA Rule 3110(e) concerning the responsibility of FINRA member firms to investigate...more

1/13/2015 - Background Checks FINRA Registration SEC

FINRA Issues Annual Regulatory and Examination Priorities Letter for 2015

One January 6, the Financial Industry Regulatory Authority issued its annual letter to FINRA member firms outlining FINRA’s regulatory and examination priorities for the coming year....more

1/13/2015 - Anti-Money Laundering Broker-Dealer Cybersecurity Examination Procedures FINRA Private Placements Regulatory Standards

Corporate and Financial Weekly Digest - Volume X, Issue 1

In this issue: - SEC Proposes Rule Amendments to Implement JOBS Act Registration Thresholds - ISS Releases FAQs on Equity Plan Scorecard and Independent Chair Policy - FINRA Issues Annual Regulatory and...more

1/12/2015 - CFTC CME Equity Plans FCMs FINRA Independent Boards ISS JOBS Act NASD No-Action Relief REITS SEC Strategic Enforcement Plan

FINRA Proposes Rule Change to Codify Reporting Requirement for Accounts Acting in Concert

On December 11, the Financial Industry Regulatory Authority proposed a rule change to amend FINRA Rule 2360(b)(5) to reflect the current requirement that reporting rules apply to all accounts acting in concert. FINRA Rule...more

12/23/2014 - FINRA Proposed Amendments Reporting Requirements Stock Options

FINRA Proposes Rule Change to Identify Transactions with Non-Member Affiliates

The Financial Industry Regulatory Authority proposed a rule change to amend FINRA Rule 6700 Series to require member firms to identify transactions with non-member affiliates in Trade Reporting and Compliance Engine reports...more

12/23/2014 - Affiliates FINRA Proposed Regulation Reporting Requirements

FINRA Issues Notice on TRACE Trade Reporting Obligations

On November 21, the Financial Industry Regulatory Authority released Regulatory Notice 14-53 to remind FINRA member firms of their Trade Reporting and Compliance Engine (TRACE) trade reporting obligations for transactions in...more

12/10/2014 - Alternative Trading Systems FINRA Reporting Requirements Securities TRACE

Corporate and Financial Weekly Digest - Volume IX, Issue 47

In this issue: - SEC Sets October 2015 Target Date for Certain Dodd-Frank and JOBS Act Rulemaking - FINRA Issues Notice on TRACE Trade Reporting Obligations - NFA Issues Guidance on Exempt and Excluded...more

12/8/2014 - AIFM Bank Secrecy Act Banks Bitcoins BitLicense C-Suite Executives CPOs CTA Dodd-Frank Enforcement Actions EU EU Data Protection Laws False Statements FFIEC FINRA Investment Funds JOBS Act NFA OCC Proposed Amendments Regulatory Standards Rulemaking Process SEC TRACE Whistleblower Awards

FINRA and the MSRB Release Companion Proposals That Would Require Additional Disclosures for Transactions in Fixed Income...

On November 17, the Financial Industry Regulatory Authority, Inc. and the Municipal Securities Rulemaking Board (MSRB) released companion proposals that would require disclosure of pricing reference information in customer...more

11/25/2014 - Disclosure Requirements FINRA Fixed Income Investments MSRB

Corporate and Financial Weekly Digest - Volume IX, Issue 46

In this issue: - US Court of Appeals for the District of Columbia Circuit Grants Petition for Rehearing of Decision on Conflicts Minerals Rule - Register for Our 2015 Proxy Season Update Webinar - SEC...more

11/24/2014 - Amnesty International Appeals CFTC Conflict Mineral Rules Crowdfunding Disclosure Requirements EU European Commission False Claims Act FinCEN FINRA Fixed Income Investments Forward Contract Exclusion Forward Contracts MSRB Proxy Season Proxy Voting Guidelines SEC Swap Dealers

FINRA's New Consolidated Supervision Rules: A Roadmap to Compliance

The Financial Industry Regulatory Authority (FINRA) has adopted comprehensive new consolidated rules regarding supervision of member firms' activities, which become effective on December 1. While the new FINRA rules...more

11/12/2014 - Compliance FINRA London Stock Exchange NASD NYSE

FINRA Proposes to Revise Implementation Date for Supplemental Inventory Schedule

On October 10, the Financial Industry Regulatory Authority, Inc. proposed a rule change to revise the implementation date for the Supplemental Inventory Schedule (SIS) approved in SR-FINRA-2014-025. The due date for the first...more

10/22/2014 - Compliance Disclosure FINRA

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