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Financial Industry Regulatory Authority (FINRA) Public Comment

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

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Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Goodwin

FINRA Proposes Remote Inspection Pilot Program

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​​​​​​​FINRA recently proposed amendments to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year pilot program (Pilot Program) to allow member firms to conduct remote branch office inspections.  In a nod to where...more

Goodwin

SEC Proposes Short Sale Disclosure Rule and Reopens Comment Period for Reporting on Securities Loans

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more

Goodwin

Stress Test Scenarios Released for 2022

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In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Morgan Lewis

Securities Lending: SEC Proposes Sweeping Rule Requiring Reporting of Transactions to FINRA

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The US Securities and Exchange Commission’s proposed Rule 10c-1 would create a sweeping new reporting and disclosure regime for participants in the securities lending markets. Among other things, the proposal increases the...more

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FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

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FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

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In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more

Goodwin

Tenth Circuit Upholds District Court’s Ruling Finding No Breach of Fiduciary Duties in Section 36(b) Case

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In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more

Goodwin

Fed Proposes Guidelines for Access to Master Accounts and Payment Services

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In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more

King & Spalding

FINRA Seeks Feedback on Pandemic-Related Impacts and Lessons

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On December 16, 2020, FINRA issued Regulatory Notice 20-42 announcing a retrospective rule review to seek comments on “Lessons From the COVID-19 Pandemic.” In the notice, FINRA requests interested parties to provide...more

White and Williams LLP

Finders May Finally Be Keepers: SEC Proposes Rules Allowing for Unregistered Broker-Dealers to Participate in Capital-Raising...

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The ability to raise capital is one of the most critical challenges facing small businesses in the U.S. today. Capital can allow for exponential growth of a well-run startup with a good idea, but the lack of capital is the...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

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In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Goodwin

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

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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

Sullivan & Worcester

SEC Proposes Amendments to Definitions of “Accredited Investor” and “Qualified Institutional Buyer”

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The U.S. Securities and Exchange Commission (the "SEC") proposed on December 18, 2019 amendments to, among other things, its current rules under the Securities Act of 1933 (the "Securities Act") relating to the definitions of...more

Eversheds Sutherland (US) LLP

FINRA once again delays implementation of amendments to FINRA rule 4210

The Financial Industry Regulatory Authority, Inc. (FINRA) filed a proposed rule change with the Securities and Exchange Commission (SEC) on October 25, 2019, to once more delay the implementation of amendments to FINRA Rule...more

UB Greensfelder LLP

FINRA’s Secret Power To Control Information

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In the past week, I ran across two discrete instances in which FINRA acts as a secret gatekeeper of sorts, exercising its own subjective judgment, without anyone knowing what, exactly, it is doing or why, employing...more

UB Greensfelder LLP

FINRA’s Proposal On High-Risk Firms Is A Must-Read, But Hardly A Must-Enjoy

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I apologize for all the posts this week, but I am traveling and am in a different time zone, so I am awake at hours when, ordinarily, I would be asleep, giving me time to muse. Anyway, given that, I will not test your...more

UB Greensfelder LLP

The Disturbingly Cozy Relationship Between FINRA And PIABA

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What exists at the point where PIABA’s transparent self-interest in getting paid and FINRA’s historical lack of transparency about who is actually driving its agenda regarding arbitrations? This: a late December decision by...more

Bergeson & Campbell, P.C.

EPA Releases Draft Human Health and Ecological Risk Assessments for Glyphosate for Public Comment

On December 18, 2017, the U.S. Environmental Protection Agency (EPA) announced it is releasing for public comment the draft human health and ecological risk assessments for glyphosate. ...more

Stinson - Corporate & Securities Law Blog

FINRA Solicits Comments on Rules Impacting Capital Formation and Proposed Changes to the Corporate Financing Rule

In what seems to be a bow to the Trump Administration, FINRA has issued Regulatory Notice 17-14 which broadly seeks comments on FINRA rules that impact capital formation. ...more

A&O Shearman

US Federal Reserve Board Announces Plans to Collect Data from Banks on Secondary Market Transactions in US Treasury Securities

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The US Federal Reserve Board announced that it plans to begin collecting data on Treasury security secondary market transactions from banks. The Federal Reserve Board intends to negotiate with the Financial Industry...more

Goodwin

Financial Services Weekly News - September 2016 #3

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Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

Goodwin

Financial Services Weekly News - August 2016 #5

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Editor's Note - Investment Advisers Breathe a Sigh of Relief. On Thursday, August 25, the federal district court in New Jersey ruled after a 26-day trial in favor of AXA Equitable Insurance Company and against the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FINRA Seeks Comments on Proposed Gift Rule Changes

The Financial Industry Regulatory Authority (FINRA) has filed a regulatory notice seeking comment on proposed changes to its gift, business entertainment and noncash compensation rules for broker-dealers. Comments must be...more

Morrison & Foerster LLP - JOBS Act

SEC Proposed Rulemaking Regarding Requirements for Transfer Agents

On December 22nd, 2015, the Commission issued an advanced notice of proposed rulemaking (ANPR) for new requirements for transfer agents, together with a concept release requesting public comment on the Commission’s broader...more

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