NFA Chairman Chris Hehmeyer Talks Bankruptcy Reform
Confirmations: NFA and CME’s Financial Match.com
Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more
A DC Circuit Court of Appeals challenge to a recent Financial Industry Regulatory Authority (FINRA) enforcement action brings into question whether FINRA should be held accountable to constitutional restrictions on state...more
Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more
NFA Adds Virtual Currency and Micro Contract Questions to Annual Questionnaire On December 6, 2021, the National Futures Association (NFA) released Notice I-21-42 to notify NFA members that new questions had been added to the...more
SEC/CORPORATE - SEC Statements Regarding SPACs Address Warrants and Projections - Following the increase in the number of special purpose acquisition companies (SPACs) and the related business combinations between SPACs...more
BROKER-DEALER - 2021 Advisory Committee Overview and Engagement Notice - On March 26, the Financial Industry Regulatory Authority (FINRA) published a notice encouraging employees of member firms and other interested...more
BROKER-DEALER - SEC Issues Amendments, Seeks Public Comment on Holding Foreign Companies Accountable Act - On March 24, the Securities and Exchange Commission adopted interim final amendments to implement...more
SEC/CORPORATE - Acting SEC Chair Lee Provides Public Statement Welcoming Public Comment on Climate Change Disclosures - On March 15, Acting Securities and Exchange Commission Chair Allison Herren Lee made a public...more
BROKER-DEALER - SEC Issues No Action Letter on Treatment of Reserved Powers Trust as Non-US Person by Non-US Investment Adviser for Registration Exemption - On March 5, the Securities Exchange Commission’s Division of...more
SEC/CORPORATE - SEC Staff Releases Sample Comment Letter on Securities Offerings During Periods of Market and Price Volatility - On February 8, the staff of the SEC’s Division of Corporation Finance (the Staff)...more
SEC/CORPORATE - SEC Proposes Rule 144 Tacking Amendments - On December 22, 2020, the Securities and Exchange Commission voted to propose amendments to Rule 144 under the Securities Act of 1933 (the Securities Act)...more
BROKER-DEALER - SEC Adopts Rules to Modernize Infrastructure for NMS Market Data - On December 9, the Securities and Exchange Commission adopted final rules that aim to modernize the infrastructure related to the...more
SEC/CORPORATE - SEC Issues C&DI on Use of Form S-3 by SPACs - On September 21, the Division of Corporation Finance of the Securities and Exchange Commission issued a new Compliance and Disclosure Interpretation (C&DI)...more
BROKER-DEALER - FINRA Announces Updates to Interpretations of Margin Rule Regarding Control and Restricted Securities and Consolidation of Accounts - On July 2, the Financial Industry Regulatory Authority (FINRA) issued...more
SEC/CORPORATE - SEC Division of Corporation Finance Issues Additional Disclosure Guidance Related to COVID-19 Pandemic - On June 23, the Division of Corporation Finance (the Division) of the Securities and Exchange...more
BROKER-DEALER - CBOE Exchange Proposes to Temporarily Extend the Filing Deadline for Certain Supervision-Related Reports - On June 1, Cboe Exchange, Inc. (Cboe) filed with the Securities and Exchange Commission a...more
BROKER-DEALER - SEC Amends CAT NMS Plan - On May 15, the Securities and Exchange Commission adopted amendments to the national market system plan governing the consolidated audit trail (the CAT NMS Plan). The Financial...more
BROKER-DEALER - FINRA Proposes Rule Change to Temporarily Amend Certain Timing, Method of Service and Other Procedural Requirements in FINRA Rules - On May 8, the Financial Industry Regulatory Authority (FINRA) filed...more
The US Securities and Exchange Commission, Financial Industry Regulatory Authority, Commodity Futures Trading Commission, and National Futures Association have each announced temporary regulatory relief for market...more
As the world responds to COVID-19, we have identified a number of compliance and legal considerations for asset managers. We summarize a select list of these in our note below....more
The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more
The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more
The Commodity Futures Trading Commission published in the Federal Register on December 10, 2019 several amendments to the regulatory framework applicable to certain commodity pool operators (CPOs) and commodity trading...more
• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more
BROKER-DEALER - FINRA Expands Transparency Initiative Related to OTC Equity Trading Volume - The Financial Industry Regulatory Authority (FINRA) previously announced an expansion to its ongoing transparency initiative...more