News & Analysis as of

Broker-Dealer Fixed Income Investments

WilmerHale

FINRA’s 2024 Annual Regulatory Oversight Report: What Broker-Dealers Need to Know

WilmerHale on

On January 9, 2024, the Financial Industry Regulatory Authority published its 2024 FINRA Annual Regulatory Oversight Report. Previously titled Report on FINRA’s Examination and Risk Monitoring Program, the Report is released...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Grants Broker-Dealers Permanent Exemptive Relief From Rule 15c2-11 for Fixed-Income Securities Sold Under Rule 144A Safe...

On October 30, 2023, the Securities and Exchange Commission (SEC) issued an order granting broker-dealers exemptive relief from Rule 15c2-11 of the Securities Exchange Act of 1934 for fixed-income securities sold in...more

Cadwalader, Wickersham & Taft LLP

SEC Exempts Brokers and Dealers from Rule 15c2-11 Review and Recordkeeping Requirements for Quotations on 144A Fixed Income...

On October 30, 2023, the Securities and Exchange Commission issued an order (the “Order”) that grants exemptive relief under Rule 15c2-11 under the Securities Exchange Act of 1934 to brokers and dealers that publish...more

Dechert LLP

Sweet Relief? SEC Exempts Fixed-Income Rule 144A Securities from Rule 15c2-11—But Questions Remain

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On October 30, 2023, after continued pressure from legislators and industry participants—and a recent lawsuit—the SEC issued an order providing relief for fixed-income securities sold pursuant to Rule 144A from the public...more

White & Case LLP

Rule 144A Fixed Income Securities Won’t Become Subject to Public Information Requirement under Rule 15c2-11

White & Case LLP on

On October 30, 2023, the US Securities Exchange Commission (the "SEC") issued an order (the "Order")1 granting broker-dealers exemptive relief from Rule 15c2-11 ("Rule 15c2-11") under the US Securities Exchange Act of 1934...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

Cadwalader, Wickersham & Taft LLP

Rule 15c2-11 Update: The SEC Provides Temporary Relief for Fixed Income Rule 144A Securities Until January 4, 2025

The SEC’s Division of Trading and Markets issued a new no-action letter yesterday that removes the requirement that Rule 144A information be made publicly available prior to a broker-dealer publishing a quotation or...more

Goodwin

Is the SEC Still Considering Fixes to the Bond Markets?

Goodwin on

The SEC has made a concerted effort in recent years to look more closely at the fixed income markets. But under the new leadership of Chairman Gary Gensler, that spotlight seemed to have dimmed—or so some thought....more

Dechert LLP

Lessons from FINRA’s 2019 Report on Examination Findings and Observations

Dechert LLP on

The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...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

Broker-Dealer Compliance + Regulation

FINRA updates its Frequently Asked Questions on new mark-up and mark-down disclosure rules for transactions in fixed income...

On March 19, 2018, FINRA updated its guidance on its recent amendments to Rule 2232. The new requirements, which are currently scheduled to take effect on May 14, 2018, apply to transactions with retail customers (not...more

Katten Muchin Rosenman LLP

Bridging the Week - February 2016 #5

CFTC Advisory Committee Says There Is No Evidence Justifying Proposed New Position Limits: A report issued by the Energy and Environmental Markets Advisory Committee of the Commodity Futures Trading Commission roundly...more

Burr & Forman

OCIE Warns on Suitability in Retail Sales of Structured Products

Burr & Forman on

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a recent “Risk Alert” noting observed deficiencies in broker-dealer supervision and compliance controls over retail sales of structured products –...more

Katten Muchin Rosenman LLP

SEC 2015 Examination Priorities Focus on Liquid Alternatives and Fixed-Income Funds

On January 13, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released its 2015 examination priorities for investment companies, investment advisers, broker-dealers and...more

Dechert LLP

SEC’s Division of Investment Management Issues Recommendations for Funds and Fund Advisers in Light of Reduced Market-Making...

Dechert LLP on

The Division of Investment Management (“Division”) of the U.S. Securities and Exchange Commission (“SEC”) recently published guidance (“Guidance”) addressing steps that funds and fund advisers should consider in light of...more

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