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Broker-Dealer Section 5

Goodwin

Overdraft Protection Programs: Risk Management Practices

Goodwin on

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

Perkins Coie

The SEC and Digital Assets—A Busy Year End

Perkins Coie on

The end of the year has been a very busy time for the SEC in the digital asset space. From speeches to the issuance of joint statements to enforcement actions, there are many things to highlight, discuss and consider. This...more

Akin Gump Strauss Hauer & Feld LLP

SEC Provides Guidance on “General Solicitation” in C&DIs and No-Action Letter

On August 6, 2015, the Staff of the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued new compliance and disclosure interpretations (C&DI Questions 256.23 through 256.33) regarding the meaning...more

Blank Rome LLP

Broker-Dealers Ignoring Red Flags Lead to SEC Releases and Enforcement Action

Blank Rome LLP on

In October 2014, the SEC’s Division of Trading & Markets issued FAQs to remind broker-dealers of their obligation to conduct a reasonable inquiry when selling securities in an unregistered transaction in reliance on Section...more

Eversheds Sutherland (US) LLP

What Does It Take to Make the SEC Happy? SEC Criticism of Broker-Dealers’ Due Diligence for Sales of Unregistered Securities...

To ensure that broker-dealers (BDs) do not inadvertently facilitate an unlawful distribution of securities, the Securities and Exchange Commission has long required BDs to conduct a “reasonable inquiry” into the circumstances...more

Broker-Dealer Compliance + Regulation

Pre-IPO Selling Procedures Need to Be Adequately Supervised, According to FINRA

Broker-dealers selling interests in IPOs need to have adequate supervisory systems to ensure that registered representatives do not make actual sales before the securities are registered, according to a settlement of a formal...more

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