Lloyd S. Harmetz

Lloyd S. Harmetz

Morrison & Foerster LLP

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FINRA Fine Addresses Broker Compensation and Conflicts of Interest

A recent enforcement action by FINRA underscores the regulator’s continuing concern regarding how financial advisers are paid to sell investment products. In a case announced on November 28, 2016, a member firm settled...more

11/30/2016 - Broker-Dealer Brokers Conflicts of Interest Financial Adviser Financial Products FINRA Investors

Structured Thoughts: News for the financial services community, Volume 7, Issue 11

Structured Products Legal and Regulatory Conference: November 2016 - In November 2016, Morrison & Foerster LLP sponsored Risk magazine’s annual structured products legal and regulatory conference in Washington, D.C. ...more

11/18/2016 - Cross-Selling DOL ETNs Fiduciary Rule FINRA International Regulatory Standards Nasdaq Packaged Retail And Insurance-Based Investment Products (PRIIPS) SEC Structured Financial Products

Inside FINRA’s “Cross-Selling Sweep”

In response to recent highly-publicized scrutiny of bank cross-selling practices, FINRA announced in October 2016 that it is conducting a sweep of broker-dealers to determine the extent to which they are...more

11/3/2016 - Banks Broker-Dealer Cross-Selling FINRA

FINRA Proposes Rules to Protect Seniors from Financial Exploitation

In October 2016, FINRA filed with the SEC proposed rules designed to help brokers protect seniors and other vulnerable adults from financial exploitation. The proposal would amend existing customer account information rules...more

10/26/2016 - Broker-Dealer Brokers Exploitation FINRA Proposed Rules Safe Harbors SEC

Structured Thoughts: News for the financial services community, Volume 7, Issue 10

FINRA Revises its Proposed Amendments to Rule 2210 - In our recent Client Alert, we wrote about the Financial Industry Regulatory Authority, Inc.’s proposed changes to Rule 2210, Communications with the Public. One of...more

10/6/2016 - Administrative Proceedings Broker-Dealer Enforcement Actions Exchange-Traded Products FINRA Mortgage REITS NASAA Proposed Amendments Rule 2210 SEC

Structured Thoughts: News for the financial services community, Volume 7, Issue 9

Updating Unregistered Structured Note Programs: How Frequently? - For some types of securities offering programs, we have “black letter law” that instructs issuers how frequently the program documentation should be...more

9/15/2016 - BaFin Bank Holding Company Brokerage Accounts Cease and Desist Orders Duty to Update Federal Reserve Financial Sector FINRA Fixed Income Investments Germany Income Tax Act Private Funds SEC Subsidiaries TLAC TRACE

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

8/13/2016 - Administrative Proceedings Broker-Dealer Disclosure Requirements Distributors DOL ERISA ETFs EU Fiduciary Duty Financial Markets FINRA Fraud Manufacturers Negligence Standard Referendums Required Communications SEC Structured Financial Products UK UK Brexit

FINRA Study of Financial Literacy: Many Investors May Not Have It

In July 2016, FINRA’s Investor Education Foundation released the findings from its National Financial Capability Study. The study suggests that, while in some ways Americans have increased their financial literacy, too...more

7/14/2016 - Broker-Dealer Financial Literacy FINRA Surveys

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

Financing Subsidiaries and SEC Registration - As readers of this publication know, in order to address the expected new U.S. regulatory capital requirements, a number of U.S. bank holding companies have been creating new...more

7/7/2016 - Bonds Complex Financial Products EU Federal Reserve Financial Services Industry Financing FINRA Global Systemically Important Financial Institutions (GSIFI) Investor Advisory Committee Investors ISDA SEC Securities Structured Financial Products Subsidiaries UK UK Brexit

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

6/17/2016 - Broker-Dealer Compliance ETFs FINRA Investment Firms NASD Sanctions Settlement

Massachusetts Securities Division Searches for Rogue Brokers

According to news reports, the Massachusetts Securities Division (the “Division”) recently sent a “sweep letter” to firms asking broker-dealers to report information about their hiring policies and procedures. The Division,...more

6/8/2016 - Broker-Dealer Enforcement Actions FINRA Hiring & Firing Professional Misconduct Securities

FINRA Proposes Initial Round of Amendments to Communications Rules

In May 2016, FINRA filed with the SEC proposed revisions to its communications rules that include a few substantive revisions to existing rules, ease some burdensome filing requirements, and leave the door open for future...more

6/7/2016 - Amended Regulation Disclosure Requirements Educational Communications Rule Filing Requirements FINRA Investment Companies Investor Protection Rule 2210 SEC

Structured Thoughts: News for the financial services community, Volume 7, Issue 6

Structured Notes Offered on an Agency Basis - In our last issue, we discussed the potential impact of the Department of Labor’s new rules on sales of structured products. In that article, we discussed some of the...more

5/31/2016 - Comment Period Debt Deposit Accounts DOL FDIC FINRA Offerings Recordkeeping Requirements Regulation S-K Retirement Plan SEC Structured Financial Products Underwriting

“It’s Not a Culture War” – Yet?

On May 23, 2016, at FINRA’s annual conference in Washington, D.C., Richard Ketchum, FINRA’s chairman and CEO, delivered a speech that shed a little light on FINRA’s recent sweep letter relating to firm culture....more

5/26/2016 - Broker-Dealer Corporate Culture Fiduciary Duty FINRA Investment Adviser Investor Protection

Structured Thoughts: News for the financial services community, Volume 7, Issue 5

Electronic Structured Product Systems and FINRA’s Robo-Advisor Report - In a prior issue of this publication, we wrote about electronic structured note issuance platforms, and how these might be affected by U.S....more

5/2/2016 - Broker-Dealer European Securities and Markets Authority (ESMA) Financial Adviser FINRA OCC Regulation S-K Retail Investors SEC

Investment Management Legal + Regulatory Update - April 2016

Regulation - Department of Labor Issues Fiduciary Regulations Under ERISA - The Department of Labor (DOL) issued its long-anticipated final regulation (the “Regulation”) defining who is a fiduciary as a result of...more

4/21/2016 - Broker-Dealer CFTC Crowdfunding Derivatives DOL ERISA FINRA SEC

Structured Thoughts: News for the financial services community, Volume 7, Issue 4

Structured Product Sales at Bank Branches: Networking- Arrangement Rules - Many broker-dealers engaged in the structured products industry are affiliates of large U.S. banks, which have a significant customer footprint. ...more

4/1/2016 - Banks Broker-Dealer Financial Services Industry FINRA High-Yield Markets SEC Structured Financial Products

FINRA Reports on Robo-Advisors

In response to the emerging growth and use of so-called “robo-advisors,” including coverage in the media, FINRA released a report in March 2016 relating to these digital investment tools. ...more

3/29/2016 - Broker-Dealer FINRA Investors Robocalling

FINRA and T+2: The Rule Roll-Out Begins

As the U.S. financial markets commence their move towards a T+2 settlement period, FINRA has introduced a proposed set of rule changes designed to support this change. The current timetable contemplates that the changes...more

3/8/2016 - FINRA Rulemaking Process Securities Settlements

Structured Thoughts: News for the financial services community, Volume 7, Issue 3

Structured Product Sales at Bank Branches: Networking- Arrangement Rules - Many broker-dealers engaged in the structured products industry are affiliates of large U.S. banks, which have a significant customer footprint....more

3/3/2016 - Broker-Dealer Corporate Communications FINRA High-Yield Markets Investors Recruitment Policies SEC Structured Financial Products

FINRA Approves Price Disclosure Proposal for Debt Securities

On February 26, 2016, FINRA issued a press release (http://www.finra.org/newsroom/2016/finra-approves-enhanced-price-disclosure-retail-investors-fixed-income-securities) announcing that its Board of Governors approved the...more

3/2/2016 - Debt Securities Disclosure Requirements FINRA SEC TRACE

“Tell Us About Your Culture” – FINRA Commences Sweep

In its January 2016 annual exam priorities letter, FINRA announced that it would examine the “compliance culture” at member firms. In furtherance of that goal, in February 2016, FINRA issued a “sweep letter” to members...more

2/23/2016 - Compliance Corporate Culture Examination Priorities FINRA Risk Management

FINRA Reminds Members of Obligations in Offerings Subject to a Contingency

On February 8, 2016, FINRA released Regulatory Notice 16-08 relating to the contingency offering requirements of Rules 10b-9 and 15c2-4 under the Exchange Act. The Notice arises from FINRA’s review of various private...more

2/12/2016 - Broker-Dealer Escrow Accounts Filing Requirements FINRA Offerings Private Placements Required Documentation Securities Exchange Act

Structured Thoughts: News for the financial services community, Volume 7, Issue 2

Is There a Standard Form of Rule 144A Representation Letter? - My file of Rule 144A representation letters has been growing fatter, and I‘m not sure why. I would have hoped that by now there would be just one great...more

2/12/2016 - Banking Sector Broker-Dealer Corporate Issuers Disclosure Requirements ERISA Federal Reserve FINRA Institutional Investors IRS Market Basket Regulation S-K Representations and Warranties Rule 144A Rule 15a-6 SEC Structured Finance Structured Financial Products TLAC

Structured Thoughts: News for the financial services community, Volume 7, Issue 1

T+2 Settlement and Structured Notes - Introduction - In December 2015, the “T+2 Industry Steering Committee” published its Implementation Playbook. The Playbook is intended to provide, among other things, a...more

1/18/2016 - Equity Markets FINRA OCIE Regulatory Agenda SEC Structured Finance Structured Financial Products

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