The compliance date of June 30, 2020, is looming for U.S. broker-dealers subject to Regulation Best Interest (Reg. BI) and broker-dealers and investment advisers required to prepare and provide relationship summaries pursuant...more
5/19/2020
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Conflicts of Interest ,
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SEC Examination Priorities ,
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Standard of Conduct
On August 9, 2018, Kenneth A. Blanco, Director of the Financial Crimes Enforcement Network (FinCEN), delivered remarks at the 2018 (Legal) Tech Conference at Chicago-Kent College of Law at Illinois Institute of Technology. ...more
The Securities and Exchange Commission (SEC) finally provided some good news, and guidance, regarding permissible token sales. On June 14, 2018, William Hinman, Director of the SEC Division of Corporation Finance, speaking at...more
This past week was a busy one for state securities regulators, the CFTC and the SEC as they continue their focus on rooting out fraud from the digital currency space and crypto- and blockchain-based ventures. Noteworthy...more
On February 7, 2018, the New York State Department of Financial Services (NY DFS) issued guidance to all virtual currency businesses that maintain a “BitLicense” or that are chartered as a limited purpose trust company under...more
On February 7, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2018 Examination Priorities. In what comes as no surprise, the exam priorities include initial coin offerings (ICOs) and...more
On February 5, 2018, new FINRA Rule 2165 (Financial Exploitation of Specified Adults) becomes effective, as does an amendment to existing FINRA Rule 4512 (Customer Account Information). Together, these rules will implement...more
On January 19, 2018, SEC Co-Enforcement Directors Stephanie Avakian and Steven Peikin and CFTC Enforcement Director James McDonald issued the following joint statement regarding virtual currency enforcement actions...more
On January 8, 2018, the Financial Industry Regulatory Authority (FINRA) released its 2018 Annual Regulatory and Examination Priorities Letter (Exam Priorities Letter) for its broker-dealer members. In the Exam Priorities...more
On the same day that a meteorological blizzard slammed the Eastern Seaboard, U.S. financial regulators unleashed their own flurry of statements and warnings surrounding initial coin offerings (ICOs) and cryptocurrencies....more
The SEC Office of Investor Education and Advocacy recently issued a bulletin listing its 10 most popular Investor Alerts and Bulletins for 2017. Numbers 1 (Initial Coin Offerings) and 2 (Public Companies Making ICO-related...more
Major derivatives market operators CBOE Holdings and CME Group have jumped into the digital currency fray within the last two weeks by launching cash-settled bitcoin futures contracts. The exchanges recently cleared de facto...more
The Securities and Exchange Commission (SEC) recently issued two warnings about investments sold on the basis of celebrity endorsements, including one relating to initial coin offerings (ICOs), and followed up with...more
Pursuant to its LabCFTC initiative, the regulator issued a FinTech Primer on virtual currencies, including addressing the jurisdictional reach of the CFTC and the SEC (and potential overlap). Several questions remain...more
Pursuant to its LabCFTC initiative, the regulator issued a FinTech Primer on virtual currencies, including addressing the jurisdictional reach of the CFTC and the SEC (and potential overlap). Several questions remain...more
The new SEC Enforcement Cyber Unit will target cyber-related misconduct, including violations involving distributed ledger technology, initial coin offerings and misconduct perpetrated using the dark web....more