Susan S. Krawczyk

Sutherland Asbill & Brennan LLP

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Florida Legislature Relaxes Agency Licensing Requirements for Broker-Dealer Branch Offices Selling Insurance Products but Creates...

Under current Florida insurance laws, branch offices of broker-dealers selling insurance products in Florida are required to either “license” or “register” as agency branches (in addition to satisfying insurance producer...more

8/26/2014 - Broker-Dealer Disclosure Requirements Insurance Brokers Insurers Licensing Rules New Regulations

FinCEN Customer Due Diligence Rule Proposal

On July 30, 2014, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules (the “Proposed Rules”) to clarify and strengthen customer due diligence requirements for banks, securities...more

8/20/2014 - Banks Broker-Dealer Commodity Pool Due Diligence FCMs Financial Regulatory Reform FinCEN Mutual Funds

M&A Brokers Exempt from SEC Broker-Dealer Registration Requirements

On January 31, 2014, the U.S. Securities and Exchange Commission’s (SEC) Division of Trading and Markets issued a No-Action Letter (Letter)1 that allows a private business broker (M&A Broker) to receive transaction-based...more

2/10/2014 - Broker-Dealer No-Action Letters Registration SEC Securities Exchange Act

SEC and FINRA Publish 2014 Examination Priorities for Broker-Dealers

On January 9, 2014, the U.S. Securities and Exchange Commission (SEC) published its 2014 examination priorities (SEC Letter), just one week after the Financial Industry Regulatory Authority (FINRA) published its 2014...more

1/20/2014 - Broker-Dealer FINRA SEC

Ready or Not: Lost Securityholders, Uncashed Checks and Dormant Accounts

In the dog days of August, it would be tempting to put aside challenges created by new Securities and Exchange Commission (SEC) rules. But we all know that would be a mistake. Instead, attention needs to be paid now to new...more

8/9/2013 - Bank Accounts Broker-Dealer Escheat Investigations SEC Securities Exchange Act

FINRA Reverses Course and Issues Guidance Changing Its Interpretation Regarding the Key Issues of "Potential Investors" and...

Background - FINRA’s new suitability requirement, Rule 2011, went into effect July 9, 2012. Because the rule was such a departure from prior standards, FINRA issued Regulatory Notice 12-25 (May 2012) to explain the rule...more

12/19/2012 - Broker-Dealer FINRA Investment Adviser Suitability Rule

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