Payment for Order Flow (PFOF) and Gamification: Your Questions Answered
Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion
Investment Management and Private Funds Roundtable – June 2020
Videocast: Asset management regulation in 2020 videocast series – FinTech initiatives
Videocast: Asset management regulation in 2020 videocast series – Fiduciary investment advice: The patchwork emerges
Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
Videocast: Asset management regulation in 2020 videocast series – Complying with new SEC rules for broker-dealers
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Regulation Best Interest Videocast Series: Establishing An Investment Platform Post-Regulation BI
Investment Management Update - Focus on Data Privacy and Cybersecurity
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
This Memorandum is intended to remind you of certain U.S. annual requirements that may be applicable to your business and is divided into five sections. All investment advisers (whether or not registered with the Securities...more
In response to ever increasing reports of forgery and falsification of records in the digital signature space, FINRA issued Regulatory Notice 22-18. This Notice reminds FINRA members of relevant regulatory obligations, while...more
Two Years Later, Regulation BI Remains a “Tremendous Priority” for FINRA - June 30th marked two years since the implementation of Regulation Best Interest (“Reg BI”) and the client relationship summary or Form CRS. Firm...more
CYBERSECURITY - U.S. Organizations Doing Business in China Warned of Malware in Tax Software - The Federal Bureau of Investigations (FBI) and the Cybersecurity and Infrastructure Security Agency (CISA) have issued a joint...more
While I feel I have enjoyed as much success defending respondents in FINRA Enforcement matters as anyone, I am still careful to caution clients who are unwilling to consider any settlement that going toe-to-toe with FINRA at...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
As we start the New Year, we would like to remind our clients of certain regulatory developments and upcoming deadlines for Q1 2018. New Form ADV - The new Form ADV takes a deeper dive by requiring additional...more
BROKER-DEALER - FINRA Releases New Targeted Exam Letter Regarding Order Routing Conflicts - On November 10, the Financial Industry Regulatory Authority released the contents of a new Order Routing Conflicts targeted...more
Federal District Court Approves Flash Crash Spoofer’s US $38 Million Settlement; Federal Appeals Court Appears Sympathetic to Michael Coscia’s Claim That Spoofing Prohibition Is Too Vague - The US federal court handling...more
Proficiency Requirements for Security Futures Products - The term security futures product (“SFP”) encompasses security futures and options on security futures. The term security future includes both futures on a single...more
This was the period of admissions. The SEC secured admissions in three actions over the period with beginning the week of Thanksgiving and continuing into the beginning of December. Cases filed during the period include: A...more
The Yates Memo, refocusing DOJ criminal and civil corporate investigations, continues to be the critical topic of discussion this week. The Memo, discussed here, directs that individuals be the focus of the inquiry from the...more
The Commission brought two FCPA cases this week, one of which was in conjunction with the DOJ. Both centered on the payments for gifts and travel in China. In addition, the SEC filed three manipulation cases, an action...more
In recent years, the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have heightened their expectations of what constitutes a “comprehensive” branch self-inspection program. Firms...more
Panelists at the PCAOB’s June 25 Standing Advisory Group Meeting discussed cybersecurity and the potential implications for financial reporting and auditing. Some of the highlights from the panel include the following...more
In this issue: - SEC Publishes Guidance for Investment Advisers and Proxy Advisory Firms Regarding Proxy Voting and Solicitation - SEC Division of Corporation Finance Issues C&DIs Relating to Accredited Investor...more
In a holiday shortened week, dark pools were again a focus for regulators. This week FINRA sanctioned Goldman Sachs in connection with the operation of its dark pool....more
Cybersecurity has increasingly become a critical issue for all types of businesses, few more so than broker-dealers, investment advisers and others in the financial sector. The cyber threat is much broader than customer data...more
In this issue: - SEC Requests Comment on FINRA Rules - CFTC Issues Interpretation Regarding Auditor Independence Standards - OTC Derivatives Regulators Group Issues Report to G20 - NFA...more
In this issue: - NASDAQ Launches Marketplace for Private Companies - SEC Proposes Rules to Enhance Oversight of Clearing Agencies - FINRA Proposes to Amend Rules 2210 and 2214 - CME Group Exchanges...more
The insider trading trial of former SAC Capital employee Matthew Martoma continued this week. The SEC filed one new administrative proceeding this week as Washington, D.C. and much of the East coast was blanketed with snow...more
- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more
A new service, Snapchat, has joined the constellation of social media services with potential business implications. Snapchat is a mobile application, originally aimed at teenagers, which allows users to send photos and text...more
The District Court for the District of Columbia has held that the Securities and Exchange Commission is exempt from producing documents relating to its audit, inspections, and review of the Financial Industry Regulatory...more