On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Rule 15b9-1 (“Rule 15b9-1”) under the Securities Exchange Act of 1934 (the “Exchange Act”) that generally eliminate the exemption from the requirement to become a member of a national securities association (an “Association”) – effectively, the Financial Industry Regulatory Authority, Inc. (“FINRA”) – for SECregistered broker-dealers that engage in proprietary trading of securities off the national securities exchanges (“Exchanges”) of which they are members. As a result, proprietary trading firms that can no longer rely on Rule 15b9-1 must either become members of FINRA or limit their trading activities to the Exchanges of which they are members. The Amendments become effective 60 days after publication in the Federal Register, and the compliance date is one year after publication in the Federal Register.