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
3/4/2024
/ Asset Management ,
Broker-Dealer ,
Compliance ,
Cryptoassets ,
Digital Assets ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Investment Adviser ,
Investment Firms ,
Investment Funds ,
Liquidity ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Reporting Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Shareholders ,
SRO ,
Trading Platforms
On 28 May 2024, the settlement period for substantially all transactions in US markets will be reduced by one day, from two business days after the trade date (T+2) to one business day after the trade date (T+1). While most...more
OVERVIEW - On October 7, 2020, the U.S. Securities and Exchange Commission (SEC) proposed a conditional exemption, operating as a nonexclusive safe harbor from the broker registration requirements of Section 15(a) of the...more
June 30 Implementation Deadlines & FINRA Proposes Rule Changes to Align with Regulation Best Interest - Introduction - On April 2, 2020, U.S. Securities and Exchange (“SEC”) Chairman Jay Clayton announced that the original...more
AGENDA -
- Background
- Regulation Best Interest
- Judicial Challenges to Regulation Best Interest
- Form CRS
- Interpretation of Investment Adviser’s Fiduciary Duty
- Interpretation of the “Solely Incidental” Prong...more
Placement agents in private securities offerings may have new obligations under SEC Regulation Best Interest (“Reg BI”) when dealing with natural persons. ...more
SEC ADOPTING RELEASES -
New Regulation Best Interest:
Title: Regulation Best Interest: The Broker-Dealer Standard of Conduct....more
OVERVIEW -
On June 5, 2019, the Securities and Exchange Commission (the “SEC”) adopted a series of new rules and interpretations designed to enhance the protection of retail investors and to improve the quality and...more
On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) issued a new interpretation (“Interpretation”) of the “solely incidental” prong of Section 202(a)(11)(C) of the Investment Advisers Act of 1940,...more
On June 5, 2019, the U.S. Securities and Exchange Commission (the “SEC”) adopted a final interpretation (the “Interpretation”) of the standard of conduct applicable to investment advisers (“IA”) under the Investment Advisers...more
On June 5, 2019 the Securities and Exchange Commission (“SEC” or the “Commission”) adopted Regulation Best Interest to require broker-dealers to observe a new standard of conduct when recommending securities or investment...more
Securities firms should begin reviewing their business models and account types to determine if they will be subject to a sweeping investor-protection regulatory regime recently adopted by the Securities and Exchange...more
6/21/2019
/ Best Interest Standard ,
Broker-Dealer ,
Conflicts of Interest ,
Fiduciary Duty ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Transactions ,
Standard of Care
At an Open Meeting on June 5, 2019, and after over a year of consideration, approximately 6,000 comment letters and investor testing, the Securities and Exchange Commission (“SEC” or “Commission”) formally adopted four...more
As we wait to see if the Department of Labor (DOL) will appeal the 5th Circuit’s mid-March ruling that vacated the DOL’s fiduciary rule, the Securities and Exchange Commission (SEC) is also making news on the fiduciary front....more
The pay-to-play rules have expanded to FINRA capital acquisition brokers (“CABs”) and the investment advisers who use CABs to solicit governmental entities, which include public pension funds, for investment advisory...more
On August 7, 2017, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a risk alert (the “Risk Alert”) summarizing observations from the second round of...more
The Financial Industry Regulatory Authority (“FINRA”) recently issued a notice requesting comments on the effectiveness and efficiency of its Rules 3270 (Outside Business Activities of Registered Persons) and 3280 (Private...more