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SEC Settlement Reminds Firms to Periodically Review Their Use of Models, Calculators and Tools When Making Client Recommendations

On October 2, 2024, the Securities and Exchange Commission (“SEC”) announced it had settled enforcement proceedings against Thrivent Investment Management, Inc. (“Thrivent”), a SEC dually-registered broker-dealer and...more

Balancing Supervision in a Virtual Environment: Key Points of FINRA’s New Voluntary Remote Inspections Pilot Rule

Securities regulators have long been concerned with the potential regulatory risks associated with geographically dispersed broker-dealer offices, citing the observation that the distance of these offices from compliance and...more

SEC and CFTC Agree on a Single Definition of “Digital Asset” – More is Needed: Moore & Van Allen

The Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) (collectively, the “Agencies”) jointly proposed a rule (the “Proposed Rule”) that would impact existing confidential reporting...more

Coinbase: Regulation by Enforcement? CFTC & Market Implications

A Bloomberg article last week suggests potentially more bad news is on the way for Coinbase Global Inc. (“Coinbase”). Coinbase is reportedly facing an investigation by the U.S. Securities and Exchange Commission (“SEC”) into...more

NYDFS Releases Stablecoin Guidance for NYDFS-regulated Institutions

On June 8, 2022, the New York State Department of Financial Services (“NYDFS”) released industry guidance applicable to U.S. dollar-backed stablecoins issued by NYDFS-regulated entities (the “Guidance”)...more

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Forgery and Falsification in the Digital World - FINRA Issues Reminder on Supervisory Obligations

In response to ever increasing reports of forgery and falsification of records in the digital signature space, FINRA issued Regulatory Notice 22-18. This Notice reminds FINRA members of relevant regulatory obligations, while...more

Riding the Regulatory Enforcement Train: FINRA Issues Reminder on Supervisory Liability for Chief Compliance Officers

On March 17, 2022, FINRA issued Regulatory Notice 22-10 (“Notice”), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (“CCO”). The Notice...more

SEC Announces Exam Priorities for 2022

On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more

SEC Announces Proposed Rule for Climate Risk and Greenhouse Gas Disclosures

On March 21, 2022, the U.S. Securities and Exchange Commission (“SEC”) announced a proposed rule (the “Proposed Rule”) that will require registrants to make certain climate disclosures in their registration statements and...more

FINRA Closes Out 2021 with Further Guidance on Pandemic-Related Issues for Member Firms

After extensive retrospective review of FINRA Rule 4370, which covers member firm business continuity plan (“BCP”) requirements during times of business disruption (such as the COVID-19 Pandemic), FINRA issued its...more

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