Steven Blau

Steven Blau

Shearman & Sterling LLP

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Latest Publications


Implementation Issues Arising from the Revised UK Senior Manager and Certification Regime

The UK Government recently announced that it would introduce a new statutory duty of responsibility on senior managers in all financial institutions and repeal the presumption of responsibility that would have applied to...more

11/3/2015 - Banking Sector EEA Financial Institutions FSMA Investment Funds Prudential Regulation Authority Senior Managers Insurers Regime (SMIR) UK UK Bribery Act

FINRA’s New Fixed Income Research Rule and Modifications to Equity Research Rule

The long anticipated overhaul of FINRA’s research rules has now been approved by the SEC. Most provisions of the new equity research rule will become effective on December 24, 2015, with limited provisions, including changes...more

10/6/2015 - Equity Investors Equity Research Rule FINRA Fixed Income Investments Investment Banks IPO

FINRA Publishes FAQs Regarding Research Conflicts of Interest in the Offering Process

In late May, FINRA published a set of Frequently Asked Questions regarding its equity research rule, which address interactions between issuers, research analysts, and investment bankers in various stages of the offering...more

10/6/2015 - Business Valuations Conflicts of Interest Equity Research Rule Financial Analysts FINRA General Solicitation IPO Offerings Public Offerings

FINRA Requests Comment on Proposed Rule Requiring Delivery of FINRA Disclosure Document to Customers of Transferring...

On May 27, 2015, FINRA solicited comment on a proposed rule (the “proposed rule”) that would require a firm to which a representative has recently transferred to provide material prepared by FINRA (the “FINRA Disclosure...more

8/3/2015 - Comment Period Compensation Agreements Disclosure Requirements Employment Contract FINRA Proposed Regulation Transfers

SEC Requests Comment on Proposed FINRA Rules Regarding Payment to Unregistered Persons

On September 25, 2014, the U.S. Securities and Exchange Commission (the “SEC”) solicited public comment on proposed FINRA rule changes (the “proposal”) that would substantively amend existing NASD and NYSE rules regarding...more

10/15/2014 - FINRA NASD NYSE Public Comment Registration SEC

FinCEN Proposes New Rule Requiring Identification of Beneficial Owners

This summer the Financial Crimes Enforcement Network ("FinCEN”) issued a notice of proposed rulemaking proposing a rule that, if adopted, would mandate that financial institutions require their legal entity customers to...more

9/10/2014 - Beneficial Owner CIP Covered Financial Institutions Financial Institutions FinCEN NOPR Reporting Requirements Rulemaking Process SAR

Preferring Foreign Depositors

The Federal Deposit Insurance Corporation has issued a proposed regulation intended to address an emerging issue in international banking: how to grant non-US branch deposits equal treatment with US deposits in the event of...more

4/10/2013 - FDIC International Banks

SEC Releases Responses To Frequently Asked Questions Regarding Rule 15a-6 And Foreign Broker-Dealers

On March 21, 2013, the staff of the Division of Trading and Markets (the “Staff”) of the US Securities and Exchange Commission (the “SEC”) released responses reflecting the Staff’s views on frequently asked questions (the...more

3/25/2013 - Broker-Dealer Rule 15a-6 SEC

Thinking Ahead: Breaking Down FINRA’s Revised Proposed Fixed-Income Research Rule

In the fourth quarter of 2012, FINRA published Regulatory Notice 12-42 (the “Revised Proposal”), amending its proposal for substantive regulation of fixed-income research by FINRA-member firms. The Revised Proposal represents...more

3/18/2013 - FINRA Qualified Institutional Buyers

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