In this issue:

- Mary Jo White, Nominee for Chair of the SEC, Appears Before Senate Banking Committee

- SEC Proposes Rules Regarding Technology Systems

- FINRA Amends Rules to Address Extraordinary Market Volatility

- FINRA Changes Membership Application Fees

- SEC Approves OBS Supplemental Schedule

- FCMs Required to Have Chief Compliance Officer by March 29

- CFTC Reminds Market Participants of Swap Data Reporting Requirements

- SEC Risk Alert Identifies Common Adviser Custody Rule Deficiencies

- Texas District Court Addresses Misappropriation Theory of Insider Trading

- Excerpt from "Texas District Court Addresses Misappropriation Theory of Insider Trading"

The US District Court for the Northern District of Texas recently denied a defendant’s motion for summary judgment in a Securities and Exchange Commission civil enforcement action under the “misappropriation” theory of insider trading, finding that an implicit agreement may be sufficient to establish liability.

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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