In this issue of Structured Thoughts, we discuss:
..European Commission consultation on EU benchmark regulation
..FINRA: Suitability and sales practices remain an issue
..SEC charges Switzerland-based dealer for selling…
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/ Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law
In this issue of Structured Thoughts, we discuss:
..FINRA sanctions for a broker for failing to reasonably supervise sales of complex securities.
..NASAA’s report warning about the risks of leveraged and/or inverse…
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/ Business Organizations, Commercial Law & Contracts, Finance & Banking, Securities Law
In this issue of Structured Thoughts, we discuss:
..The SEC’s newly released margin rules for security-based swap dealers.
..U.K.’s Financial Conduct Authority consultation on its proposal to ban the sale, marketing, and…
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/ Finance & Banking, International Law & Trade, Securities Law
In this issue of Structured Thoughts, we discuss:
..New Regulation Best Interest, and its impact on the structured products market.
..The SEC’ June 2019 request for comment on simplifying, harmonizing and improving the…
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/ Business Organizations, Finance & Banking, Securities Law
FINRA’S PROPOSED AMENDMENTS TO THE CORPORATE FINANCING RULE – IMPACT ON STRUCTURED NOTE OFFERINGS -
On April 11, 2019, FINRA filed with the SEC a diverse set of proposed revisions to Rule 5110, its Corporate Financing Rule…
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/ Business Organizations, Finance & Banking, Securities Law
FINRA RESTATES AND UPDATES GUIDANCE AS TO PRE-INCEPTION INDEX PERFORMANCE DATA -
In a January 2019 interpretative letter, the Financial Industry Authority (FINRA) provided guidance to a registered broker-dealer as to the use…
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/ Business Organizations, Finance & Banking, International Law & Trade, Securities Law
FINRA EXAMINATION FINDINGS AND STRUCTURED PRODUCT SALES -
On December 7, 2018, FINRA released its report describing its examination findings. A number of FINRA’s findings in the report directly relate to the structured…
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/ Finance & Banking
SEC FINES BROKER-DEALER FOR UNSUITABLE SALES OF LEVERAGED ETNS -
In September 2018, the SEC fined a New York-based broker-dealer in connection with unsuitable sales of leveraged ETNs linked to the price of crude oil.
In…
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/ Finance & Banking, Securities Law
UK FINANCIAL CONDUCT AUTHORITY CALLS FOR INPUT ON PRIIPS -
On July 26, 2018, the Financial Conduct Authority (FCA) of the United Kingdom issued a Call for Input in relation to the Packaged Retail and Insurance-based…
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/ Finance & Banking, International Law & Trade, Securities Law
SEC FINES BROKER-DEALER FOR EARLY RESALES OF STRUCTURED NOTES -
On June 25, 2018, the SEC announced that a broker-dealer settled charges relating to inappropriate resales of structured notes. The SEC determined that the…
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/ Finance & Banking, Securities Law
FINAL CANADIAN BAIL-IN RULES: IMPACT ON STRUCTURED NOTES OFFERED IN THE UNITED STATES -
In March 2018, the Canadian government released its final regulations relating to “bail-in instruments” issued by Canadian domestically…
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/ Business Organizations, Franchise Law, International Law & Trade, Securities Law, Taxation
FINRA 2018 EXAM PRIORITIES: SUITABILITY AND COMPLEX PRODUCTS REMAIN FRONT AND CENTER -
In January 2018, FINRA released its annual examination priorities letter.1 The letter addresses a variety of areas that are important to…
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/ Business Organizations, Commercial Law & Contracts, Finance & Banking, Securities Law
Linking to ETFs vs. Linking to Indices -
A person studying structured products issuances for the first time might think he is having a case of double vision. On the one hand, there are a variety of products linked to certain…
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/ Business Organizations, Commercial Law & Contracts, Finance & Banking
Structured Product Red Herrings: Rule 433 and Rule 424(b) -
Red herrings for most offerings of structured products registered with the Securities and Exchange Commission (the “SEC”) under the Securities Act of 1933, as…
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/ Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade
Sales of VIX-Linked ETPs – Back to Basics for FINRA -
FINRA used a misselling case to remind member firms of certain fundamentals, including the importance of implementing a new product approval process, reasonable diligence…
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/ Business Organizations, Consumer Protection, Finance & Banking, Privacy, Securities Law