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SEC Adopts Rules Requiring Certain Trading Entities, Including Certain Investment Advisers and Private Funds, to Register as...

Section 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”) defines a “dealer” as “any person engaged in the business of buying and selling securities […] for such person’s own account...more

SEC Approves FINRA Supervisory Control Rules Expanding Remote Work Options for Broker-Dealers

Financial Industry Regulatory Authority (“FINRA”) supervisory control rules require each securities broker-dealer that is a member of FINRA to categorize every location from which the business of the broker-dealer is...more

SEC Division of Examinations – 2021 Priorities

On March 3, 2021, the SEC’s Division of Examinations (“Division” or “EXAMS”) published its annual Examination Priorities Report, which identified eight primary areas of focus for Fiscal Year 2021. While many of these...more

SEC Examiners Warn of COVID-Related Compliance Risks for Broker-Dealers and Investment Advisers

The Securities and Exchange Commission (“SEC”) last week published its observations from the first five months operating the SEC’s national examination program during the ongoing COVID-19 pandemic. This is the latest...more

SEC Examination Priorities for 2020 Include Both Emerging and Existing Concerns for Registered Investment Advisers and...

On January 7, 2020, the Securities and Exchange Commission (“SEC”) issued its 2020 Examination Priorities, a yearly publication highlighting new and existing areas of focus for the Office of Compliance Inspections and...more

Regulation Best Interest: Updates and Developments

It’s been nearly five months since the Securities and Exchange Commission (“SEC”) approved Regulation Best Interest: The Broker-Dealer Standard of Conduct (“Reg BI”). As discussed in our June 27, 2019 Client Alert, Reg BI...more

Recent SEC Enforcement Actions Reinforce the Importance of Effective Supervision, Policies, and Procedures for Broker-Dealers and...

A summer of Securities and Exchange Commission settlements involving registered broker-dealers and investment advisers demonstrates that the SEC remains firmly committed to regulating the conduct of these firms. These...more

2017 Financial Industry Regulatory Priorities - OCIE and FINRA Announce Examination Areas of Focus

In early January, both the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) and FINRA announced their examination priorities for 2017. As in previous years, both the SEC and FINRA share many examination...more

Washington Insight - September 2016

House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more

The SEC’s Customer Protection Rule Initiative and Whistleblower Protection Efforts – What Broker-Dealers Need to Know

On June 23, 2016, the SEC instituted a settled enforcement action against Merrill Lynch, Pierce, Fenner & Smith Inc. and Merrill Lynch Professional Clearing Corp. (collectively, “Merrill”), in which Merrill agreed to pay $415...more

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