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Goodwin

Paying for Buy-Side Investment Research: New Rules Ease the US-UK Divide

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In our previous alert, Paying for Buy-Side Investment Research: Will the FCA’s Third Way Ease the US-UK Divide?, we discussed the consultation issued by the Financial Conduct Authority (FCA) on proposed rules on payment...more

Seward & Kissel LLP

SEC Adopts Data Privacy Rule Amendments to Regulation S-P

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Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule and Amended PTE 2020-02: Effective Date Considerations

The DOL’s new fiduciary advice rule, effective September 23, 2024, will cause many one-time recommendations to be fiduciary advice. As a result, many more recommendations to retirement investors—private sector retirement...more

Cooley LLP

Here comes T+1

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In 2023, the SEC adopted a number of new rule amendments intended to reduce risks in the clearance and settlement processes, including, significantly, a change that will reduce the standard settlement cycle for most...more

Bass, Berry & Sims PLC

T+1 = Here We Come!

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On February 15, 2023, the Securities and Exchange Commission (SEC) adopted a set of rule amendments and new rules to facilitate the shortening of the standard settlement cycle for most broker-dealer transactions from two...more

McGuireWoods LLP

Spring Has Sprung for Recent Reg NMS Reporting Changes

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On March 6, the SEC released its long-anticipated adopting release amending Rule 605. Separately, in late February, FINRA issued Regulatory Notice 24-05 discussing new FINRA Rule 6151, which requires member firms to provide...more

Seward & Kissel LLP

SEC Adopts Rules Expanding the Definitions of “Dealer” and “Government Securities Dealer”

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On February 6, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to the definitions of “dealer” and “government securities dealer” that would subject certain market participants acting as liquidity...more

UB Greensfelder LLP

[Webinar] FINRA Expungement: A Rundown of Recent Amendments Regarding Expunging Customer Dispute Information - December 14th,...

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Join Michael J. Charlillo as he discusses FINRA's latest expungement process enhancements. He will explore process changes implemented when requesting and obtaining expungement of customer dispute information. Michael will...more

WilmerHale

SEC Adopts Rules Shortening the Standard Settlement Cycle to T+1

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On February 15, 2023, the Securities and Exchange Commission (SEC or the Commission) voted to adopt rule changes to shorten the standard settlement cycle for broker-dealer transactions in securities from two business days...more

Goodwin

FINRA Extends the “Maintaining Qualifications Program” Enrollment Window for Brokerage Reps U5’d Before March 15, 2022

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Previously registered representatives who missed the prior deadline now have until December 31, 2023 to enroll.  Registered brokerage representatives historically had two years from their Form U5 filing date to...more

Goodwin

Broker-Dealer Compliance With Revamped Recordkeeping Requirements Begins May 3, 2023; FINRA Publishes Chart of “Most Significant...

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The SEC recently amended Exchange Act Rule 17a-4 by adopting new recordkeeping requirements for broker-dealers. Most notably, the SEC will no longer require broker-dealers to maintain records in “write once, read many” or...more

WilmerHale

SEC Holiday Reading List: Four Rule Proposals That Would Overhaul Market Structure and How Retail Orders Are Executed

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On December 14, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard...more

Kramer Levin Naftalis & Frankel LLP

SEC Staff Provides Relief From Rule 15c2-11 Public Financial Statement Disclosure Through Jan. 5, 2025

On Sept. 16, 2020, the Securities and Exchange Commission (SEC) adopted amended Rule 15c2-11 (the Amended Rule) under the Securities Exchange Act of 1934, as amended (the Exchange Act). The Amended Rule, most of which became...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

FINRA Extends the Registration Qualification Window from Two to Five Years After Termination

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Persons registered with a broker-dealer historically have had two years from their Form U5 filing date to re-register with another firm before their prior qualifications (examinations) would lapse. This two-year window often...more

Morgan Lewis - All Things FinReg

FINRA Files Rule Change to Extend Implementation Date of Rule 4210 TBA Changes

FINRA filed a proposed rule change with the US Securities and Exchange Commission (SEC) on August 26, 2021 to delay the effective date of changes to FINRA Rule 4210 that were previously implemented on December 15, 2016. The...more

Goodwin

FINRA Adds Continuing Membership Application Requirement to Address Brokers With a History of Misconduct

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FINRA recently amended its rules in order to strengthen its tools to respond to brokers with a significant history of misconduct and the firms that employ them. The amended rules include FINRA’s Disciplinary Proceedings...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

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On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

WilmerHale

SEC Amends Rule 15c2-11 to Enhance Publicly Available Information For Securities Quoted in the Over the Counter Markets

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The Securities and Exchange Commission (SEC) has amended Rule 15c2-11 (the amended Rule), which governs the publication of quotations in the over-the-counter (OTC) markets, i.e., quotes that are published away from a...more

Dechert LLP

SEC Updates Rule 17H Risk Assessment Thresholds for Certain Broker Dealers

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The Securities and Exchange Commission issued an order (Order)1 on June 29, 2020, under Section 17(h)(4) of the Securities Exchange Act of 1934, raising the thresholds for compliance with the recordkeeping and reporting...more

UB Greensfelder LLP

Update on the FINRA Expungement Process

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Earlier this month, the SEC approved the first of several rule changes that FINRA has proposed for the process governing the expungement of customer complaints from a broker’s record. The approved rule change will make it...more

UB Greensfelder LLP

A Modest Proposal On The Appropriate Allocation Of Fees In Expungement Cases

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A couple of years ago, I complained about PIABA’s effort to make expungement even more difficult to obtain. Well, fast forward to June 1, and, as Chris Seps explains here, the SEC has approved the first proposed expungement...more

Goodwin

Financial Services Weekly Roundup: OCC Finalizes New CRA Rule; Regulators Continue To Provide COVID-19-related Relief

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In This Issue. The Office of the Comptroller of the Currency (OCC) finalized a rule to strengthen and modernize regulations under the Community Reinvestment Act; the Securities and Exchange Commission (SEC) voted to adopt...more

Eversheds Sutherland (US) LLP

Videocast: Asset management regulation in 2020 videocast series – The annuity regulatory landscape

In this Bottom Line videocast, Dodie Kent and Clifford Kirsch discuss: The continued emergence of registered index linked annuity products. The NAIC’s amended Suitability Rule. The SEC’s variable product summary prospectus...more

Latham & Watkins LLP

SEC Approves Amendments to FINRA’s New Issue Rules

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The amendments expand certain exemptions and provide additional guidance under Rules 5130 and 5131 with respect to equity IPO allocations. On December 19, 2019, the Financial Industry Regulatory Authority (FINRA) issued...more

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