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Financial Industry Regulatory Authority (FINRA) Due Diligence

Carlton Fields

FINRA Issues 2024 Annual Regulatory Oversight Report

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FINRA issued its 2024 Annual Regulatory Oversight Report on January 9, 2024, providing a glimpse into FINRA’s current regulatory oversight of member firms and their registered personnel in 27 topic areas....more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - January 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Dechert LLP

SEC Division of Examinations Releases 2024 Priorities

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The SEC’s Division of Examinations (EXAMS) published its report on 2024 Examination Priorities on October 16, 2023. The 2024 Examination Priorities continue to reflect an examination program that is vigorous and broad...more

Dechert LLP

Artificial Intelligence: Legal and Regulatory Issues for Financial Institutions

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Over the last six months, artificial intelligence (AI) has captured the public imagination in a way it never has before. A new generation of AI-powered language models make use of a deep learning architecture known as a...more

Rumberger | Kirk

Are Broker-Dealers Acting in the Best Interests of Their Customers? ‘Not Yet,’ Says FINRA

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Noting Deficiencies, FINRA Suggests Best Practices for Reg BI Compliance - During its first-ever review of compliance with Regulation Best Interest (Reg BI), the Financial Industry Regulatory Authority (FINRA) found...more

Mayer Brown Free Writings + Perspectives

What’s the Deal? – Initial Public Offerings: Pre-Filing Period

Here’s the deal: - The pre-filing period is an important part of an initial public offering (“IPO”), requiring a number of management, organizational considerations and structural changes before a company can effectuate...more

Morgan Lewis

Outsourcing: FINRA Outlines Onboarding and Supervision Suggestions for Use of Third-Party Vendors

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A recent FINRA regulatory notice recasts existing obligations regarding outsourcing as a procedural roadmap for broker-dealers to “consider” when using third-party vendors. The Financial Industry Regulatory Authority, Inc....more

BCLP

Supervision of Vendors When Outsourcing - The Buck Stops with FINRA Member Firms

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Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more

Pillsbury Winthrop Shaw Pittman LLP

The Beginning of the SPAC Enforcement Wave: SEC Makes Example of SPAC for Spacing out on Diligence

Chair Gensler’s enforcement agenda begins to take shape as SEC brings sprawling enforcement action against wide range of SPAC participants. Consistent with prior SEC warnings regarding incentives for Special Purpose...more

UB Greensfelder LLP

FINRA Is Bearish On FinTech (For Now) With Its Record Fine Against Robinhood

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There’s no question that FinTech firms are on the rise, and attempting to revolutionize the financial services space for the better. One such FinTech firm is none other than the notorious Robinhood. A technology company at...more

UB Greensfelder LLP

For FINRA, Unlike The SEC, Blaming The BD Always Seems To Be The Answer

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FINRA Enforcement has often been accused (again, admittedly, by me, and not too infrequently) of going after the “low-hanging fruit,” that is, taking the easy case when it presents itself. Putting aside the question whether...more

BCLP

Anti-Money Laundering Continues to be Among the Highest Regulatory Priorities, As Evidenced by Recent Enforcement Cases and...

BCLP on

For the past decade, anti-money laundering (“AML”) has been at the forefront of securities regulators’ priorities.  Indeed, AML enforcement cases have resulted in some of the highest fines imposed by securities regulators,...more

Hinshaw & Culbertson LLP

FINRA Releases Annual Report Addressing Areas of Examination Focus for 2021

The Financial Industry National Regulatory Authority (FINRA) announced its 2021 report on FINRA's examination and risk monitoring program on February 1, 2021. According to FINRA, the report combines and replaces two of their...more

UB Greensfelder LLP

SEC Settlement Proves That When CCOs Spot A Problem, Silence Is Not Golden

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A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more

Ballard Spahr LLP

Placement Agents and Due Diligence: FINRA Settles With a Placement Agent for Failure to Retain Evidence of the Process and Results...

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Summary - FINRA settled with a placement agent for failing to perform due diligence and supervise an employee in connection with the placement of securities by the placement agent in a Regulation D offering....more

Sheppard Mullin Richter & Hampton LLP

FINRA Settlement Highlights Importance of Anti-Money Laundering Due Diligence and Monitoring

A recent enforcement action offers a glimpse of the Financial Industry Regulatory Authority’s (“FINRA”) expectations for firms conducting anti-money laundering (“AML”) due diligence and transaction monitoring. On July 27,...more

Vedder Price

OCIE Announces 2020 Examination Priorities

Vedder Price on

On January 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2020 examination priorities for regulated entities, including investment advisers and registered funds. The examination...more

Goodwin

Financial Services Weekly News: FDIC Releases Guide To Connect Fintechs With Banks

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more

Dechert LLP

SEC Proposes Best Interest Standard for Broker-Dealers, Related Investment Adviser Guidance and New Customer Relationship Summary...

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The U.S. Securities and Exchange Commission on April 18, 2018 published a package of proposed rules and interpretations intended to improve the retail investor experience and to provide greater clarity regarding customers’...more

Goodwin

Financial Services Weekly Roundup - June 2018 #2

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Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) issued a no-action letter that closes the gap in investor protection created by the SEC’s approval of FINRA Rule 2165; the SEC’s Investment...more

Goodwin

Financial Services Weekly News - May 2018 #2

Goodwin on

Editor's Note - Regulatory Relief, One Way or Another. It seems that banks may finally be the beneficiaries of meaningful regulatory relief and such relief is coming from several different sources. Yesterday, May 8, 2018,...more

K&L Gates LLP

FINRA’s Most Significant 2016 Enforcement Actions

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The Financial Industry Regulatory Authority (“FINRA”), the self-regulatory organization for broker-dealers, brings about 1,500 enforcement actions a year. Often lost in the volume of actions, however, are the ones that merit...more

Bass, Berry & Sims PLC

Court Orders Parties to Retry Arbitration Seven Years After Award

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In 2008, Move, Inc., initiated a FINRA arbitration against Citigroup Global Markets, alleging that Citigroup improperly invested over $131 million of Move's assets in illiquid and unsuitable auction rate securities. The...more

Mintz

EB-5 Due Diligence Matters

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Private placement offerings are an increasingly active part of the securities business. One especially complicated and emerging area of private placements is the EB-5 Investor Visa Regional Center Program. Under the current...more

Morgan Lewis

SEC Approves Rule to Regulate Debt Research Reports and Debt Research Analysts

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Background - Eight years in the making, the US Securities and Exchange Commission (SEC) has finally approved the Financial Industry Regulatory Authority’s (FINRA's) proposed Rule 2242 (the Rule or Rule 2242), which will...more

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