News & Analysis as of

Securities and Exchange Commission (SEC) Net Capital Rule

Cozen O'Connor

A Helpful Reminder for Broker-Dealers Subject to Examination by the SEC

Cozen O'Connor on

On June 5, 2024, the SEC's Division of Examinations (the Division) released a risk alert regarding the examination of broker-dealers. The alert acknowledges the diversity of the broker-dealer population in the marketplace...more

Eversheds Sutherland (US) LLP

A Goldfish is the Happiest Animal, A Securities Respondent is Not: Ted Lasso, SEC, FINRA, and DOL Enforcement Actions (October...

You know what the happiest animal on Earth is? It's a goldfish. Y'know why? It's got a 10-second memory. Be a goldfish. During the pandemic, we have had a lot of lows, as well as a few highs. And that’s just in pop...more

Fox Rothschild LLP

New SEC Division Undertakes 2021 Examination Priorities

Fox Rothschild LLP on

On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement, Corporation Finance, Trading...more

Eversheds Sutherland (US) LLP

Regulators have bank deposit sweep programs in their sights

Coming on the heels of the share class initiative, the US Securities and Exchange Commission (SEC) is at the initial stages of another initiative involving concerns about adviser disclosures and conflicts related to bank...more

A&O Shearman

Federal Reserve Bank of New York Releases Operating Policy on Market Operations Counterparties

A&O Shearman on

The New York Fed released a statement of its policies towards managing its open market operations counterparty relationships with private entities, which includes primary dealers in US Treasury securities. Generally, the New...more

Morgan Lewis

Broker-Lite: FINRA Built It, But Will They Come?

Morgan Lewis on

On August 18, 2016, the US Securities and Exchange Commission (SEC) approved a new Financial Industry Regulatory Authority (FINRA) rule series intended as a “lite” framework for the registration and regulation of brokers that...more

Dorsey & Whitney LLP

This Week In Securities Litigation

Dorsey & Whitney LLP on

The Sixth Circuit last week concluded that Morrison, which held that Section 10(b) does not have extraterritorial reach, is inapplicable to Advisers Act Section 10(b). The DC Circuit, on rehearing, reaffirmed its prior...more

Katten Muchin Rosenman LLP

FINRA Updates Its Interpretation of the SEC’s Financial Responsibility Rules

In June, the Financial Industry Regulatory Authority updated its interpretations of the Securities and Exchange Commission Rules 15c3-1 (net capital) and 15c3-3 (customer protection). Among other things, FINRA updated its...more

Katten Muchin Rosenman LLP

Commissioner Kara M. Stein Calls for More Stringent Net Capital Requirements for Broker Dealers

On June 12, Commissioner Kara M. Stein called on the Securities and Exchange Commission to make its net capital requirements for broker dealers more stringent. Commissioner Stein warned that current net capital levels may not...more

Morgan Lewis

SEC Issues FAQs on Financial Responsibility Rules

Morgan Lewis on

The guidance addresses expense arrangements, buy-in procedures, free credit balances, sweep programs, and bulk transfers, among other things. On March 6, the staff of the Securities and Exchange Commission (SEC) issued...more

Morgan Lewis

Temporary Exemption from Certain SEC Financial Responsibility Rules Amendments

Morgan Lewis on

The limited exemption will provide broker-dealers with more time to make necessary operational or systems changes. On October 17, the Securities and Exchange Commission (SEC) issued an order providing a temporary...more

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