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Examination Priorities for 2017 from FINRA and OCIE

In these uncertain times, the predictability and regularity of the annual priorities letters from FINRA and the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) is...more

Investment Management Legal + Regulatory Update - August 2016

Regulation - Next on the SEC’s Regulatory Agenda: A Chief Valuation Officer? - First, the SEC required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity...more

Structured Thoughts: News for the financial services community, Volume 7, Issue 8

Brexit and Structured Products: A Framework for Considering Disclosures - The U.K.’s recent referendum to withdraw from the European Union has affected virtually all segments of the financial industry. The structured...more

FINRA Sanctions Investment Firm Following Unsuitable Sales of Nontraditional ETFs

On June 7, 2016, FINRA settled proceedings against a New York-based investment firm for alleged violations of its suitability and related rules, namely NASD Rule 2310 and FINRA Rules 2111 and 2010. According to FINRA,...more

SEC Approves Amendments to FINRA’s Corporate Financing Rule

Broader Availability of Termination Fees and Rights of First Refusal - Elimination of Filing for Certain ETFs: In May 2014, the SEC approved FINRA’s proposed amendments to Rule 5110, commonly called the...more

Structured Thoughts -- Volume 4, Issue 1 -- January 16, 2013

In This Issue: Additional SEC Guidance on Estimated Value Disclosures; FINRA to Continue Its Focus on Structured Products; FINRA’s Ketchum Discusses Structured Products; FINRA Issues Q&A Guidance on New Communications...more

Structured Thoughts -- Volume 3, Issue 14 -- December 18, 2012

In This Issue: Dividend Adjustments on the Way; Federal Court Decision Supports Use of “Big-Boy Letters”; FINRA Updates Its Suitability Questions and Answers; FINRA Rule 5123 Excludes Some, But Not All, Options;...more

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