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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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