News & Analysis as of

Broker-Dealer Examination Priorities

Goodwin

FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers

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Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more

Goodwin

FINRA 2022 Exam Report Spotlight: Communications with the Public

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It came as no surprise that FINRA’s 2022 Examination and Risk Monitoring Program Report highlighted communications with the public as a continued area of focus. The primary theme across this focus area relates to the...more

Goodwin

FINRA Publishes 2022 Examination and Risk Monitoring Report

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On February 9, 2022, FINRA published its 2022 Report on its Examination and Risk Monitoring Program, identifying key areas of focus for broker-dealer exams this year. While each exam is unique to the firm under FINRA’s...more

Holland & Knight LLP

FINRA Issues Guidance on FinCEN AML/CFT Priorities

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The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more

UB Greensfelder LLP

[Webinar] FINRA 2021: What to Expect - February 24th, 2:00 pm - 3:00 pm EST

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Join Ulmer partners Alan M. Wolper and Michael A. Gross as they address hot topics, including recent rule changes, exam priorities, and other FINRA developments....more

Sheppard Mullin Richter & Hampton LLP

SEC and FINRA Signal Renewed Focus on Vendor Management in Two Key Areas: Cybersecurity and Market Access Rule Compliance

The Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority (“FINRA”) recently issued guidance in connection with firms’ relationships with third-party service providers. These publications...more

Dechert LLP

FINRA Issues 2020 Examination Priorities

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The Financial Industry Regulatory Authority published its 2020 Risk Monitoring and Examination Priorities Letter (Priorities Letter) on January 9, 2020. The Priorities Letter identifies four core areas on which FINRA will...more

Dechert LLP

OCIE Releases 2020 Examination Priorities

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The 2020 Examination Priorities of the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission were announced on January 7, 2020, and cover eight broad topics: - Protection...more

Perkins Coie

Blockchain Week in Review - January 2019 #4

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Cboe Withdraws and Then Submits a Proposed Rulemaking for a Bitcoin ETF - On January 22, 2019, Cboe BZX Exchange (Cboe) withdrew its proposed rulemaking with the U.S. Securities and Exchange Commission (SEC). Had the...more

K&L Gates LLP

In 2019, FINRA’s Evolution Includes Staying the Course and Focusing on Emerging Issues

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Introduction - On January 22nd, the Financial Industry Regulatory Authority (FINRA) issued its newly titled “Risk Monitoring and Examination Priorities Letter” to announce its 2019 priorities. ...more

Sheppard Mullin Richter & Hampton LLP

FINRA Announces 2019 Regulatory Priorities

On January 22, 2019, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released its annual priorities letter highlighting its regulatory program’s points of emphasis for the coming year. The most immediately...more

UB Greensfelder LLP

FINRA’s 2019 Examination Priorities Letter: Beware, More Of The Same Is Coming

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In what has become an annual, but hardly exciting – I mean, it’s not like anxiously awaiting the day that pitchers and catchers report to Spring Training – tradition, with the turning of the calendar to the new year, FINRA...more

Dorsey & Whitney LLP

OCIE Risk Alert Highlights the Most Frequent Adviser Fees and Expenses Deficiencies

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On April 12, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert identifying the most frequently cited compliance deficiencies relating to fees and expenses charged by SEC...more

Proskauer Rose LLP

SEC Staff Announces 2018 OCIE Examination Priorities

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Last week the staff of the Office of Compliance Inspections and Examinations (OCIE) of the SEC announced its 2018 examination priorities. The 2018 examination priorities include five thematic areas: (i) compliance and risks...more

Dorsey & Whitney LLP

SEC Targets Advisers With New Cooperation Initiative

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The SEC’s Division of Enforcement announced a new cooperation initiative addressed to investment advisers who have failed to disclose conflicts arising from the receipt of 12b-1 fees from mutual funds. In essence, the...more

Vedder Price

Investment Services Regulatory Update - February 2018

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New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Morrison & Foerster LLP

Examination Priorities for 2017 from FINRA and OCIE

In these uncertain times, the predictability and regularity of the annual priorities letters from FINRA and the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) is...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update – February 2017

REGULATION - DOL Issues Additional Guidance on Fiduciary Rule - On January 13, 2017, the U.S. Department of Labor (“DOL”) issued a second set of guidance on its new fiduciary rules, which are scheduled to become...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 8, Issue 1

U.S. Court of Appeals Upholds SEC’s Backtesting Finding - In a 2016 case before the U.S. Court of Appeals for the D.C. Circuit, a former investment adviser lost a petition to review and vacate the decision of an SEC...more

King & Spalding

2017 Financial Industry Regulatory Priorities - OCIE and FINRA Announce Examination Areas of Focus

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In early January, both the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) and FINRA announced their examination priorities for 2017. As in previous years, both the SEC and FINRA share many examination...more

Patterson Belknap Webb & Tyler LLP

Cybersecurity 2017: Top Exam Priorities for Federal Securities Regulators

Hedge funds and broker dealers can expect their cybersecurity preparedness to come under scrutiny again this year by federal securities regulators....more

Broker-Dealer Compliance + Regulation

FINRA Issues 2017 Examination Priorities Letter

Introduction - Consistent with prior practice, with the arrival of the new year, FINRA has published its key examination priorities. As in prior years, the letter covers a broad array of topics. This year’s topics...more

Ballard Spahr LLP

Investment Management Update

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The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more

Fox Rothschild LLP

Elder Abuse Takes Another Twist and Turn

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If you thought the SEC and FINRA were serious about elder issues, welcome to the Alabama, Indiana and Vermont. Each has focused on elder abuse issues. These states will have mandatory reporting to state officials in...more

K&L Gates LLP

FINRA Targets AML Programs and “Culture of Compliance” as 2016 Enforcement Priority, Particularly for High-Risk Broker/Dealers

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Under Securities and Exchange Commission (“SEC”) authorization, the Financial Industry Regulatory Authority (“FINRA”) is “responsible for regulating (1) all securities firms that do business with the public[,]” (2) key stock...more

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