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Recordkeeping Requirements Reporting Requirements Broker-Dealer

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

K&L Gates LLP

SEC Expands "Dealer" Definition to Capture Liquidity Providers

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Introduction - On 6 February 2024, the US Securities and Exchange Commission (SEC) voted 3-2 to adopt two new rules that significantly expand the definitions of a “dealer” and “government securities dealer” in Sections...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Goodwin

Broker-Dealer Compliance With Revamped Recordkeeping Requirements Begins May 3, 2023; FINRA Publishes Chart of “Most Significant...

Goodwin on

The SEC recently amended Exchange Act Rule 17a-4 by adopting new recordkeeping requirements for broker-dealers. Most notably, the SEC will no longer require broker-dealers to maintain records in “write once, read many” or...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

Goodwin on

Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...more

Winstead PC

Financial Regulators Focus on Preservation of Ephemeral Messaging

Winstead PC on

Recent Enforcement Action - The requirement that financial firms preserve books and records is nothing new. But how do such firms keep track of employees’ communications on applications like Signal or WhatsApp? Those...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

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In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

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

Goodwin

Agencies Approve Final Rule: Computer-Security Incident Notification

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (together, the Agencies) issued a final rule...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

BakerHostetler

SEC Adopts Amendments to Rule 15c2-11

BakerHostetler on

The Securities and Exchange Commission (the SEC or Commission) recently adopted amendments (the Amendment) to Rule 15c2-11 (the Rule) of the Securities Exchange Act of 1934 (the Exchange Act). Generally, in an effort to...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

Goodwin on

On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

Dechert LLP

SEC Updates Rule 17H Risk Assessment Thresholds for Certain Broker Dealers

Dechert LLP on

The Securities and Exchange Commission issued an order (Order)1 on June 29, 2020, under Section 17(h)(4) of the Securities Exchange Act of 1934, raising the thresholds for compliance with the recordkeeping and reporting...more

WilmerHale

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

WilmerHale on

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more

Vedder Price

SEC, NASAA and FINRA Issue Senior Safe Act Fact Sheet

Vedder Price on

On May 23, 2019, in recognition of the one-year anniversary of the passage of the Senior Safe Act, the SEC, the North American Securities Administrators Association and FINRA issued a fact sheet to raise awareness of the act...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - August 2016

Proskauer Rose LLP on

Editor's Overview - This month’s newsletter features an article on the DOL’s recently published interim final rule that increases penalties for notice and disclosure violations, which generally became effective on...more

Goodwin

Financial Services Weekly News - November 2015

Goodwin on

Regulatory Developments - Client Alert: SEC Issues New Guidance on Excluding Shareholder Proposals under Rule 14a-8: Goodwin Procter’s Capital Markets practice has released a client alert on the SEC’s Division of...more

Morrison & Foerster LLP

Following the Wisdom of the Crowd? A Look at the SEC’s Final Crowdfunding Rules

In this alert, we provide a detailed overview of the final rules, Regulation Crowdfunding, which will be applicable to crowdfunding offerings conducted in reliance on Section 4(a)(6) of the Securities Act of 1933 as amended...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

Katten Muchin Rosenman LLP

Bridging the Week - August 2015 #4

CME Group Files Disciplinary Actions for Trading Ahead of Block Trades and Failure to Supervise an Employee Engaging in Disruptive Trading Activities - In two cases of first impression, CME Group exchanges brought and...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Securities-Based Swap Recordkeeping, Reporting and Notification Requirements

On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more

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