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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

Above and Beyond: FINRA Clarifies Its Approach to Assessing Extraordinary Cooperation

FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more

The SEC Approves Regulation Best Interest: The Broker-Dealer Standard of Conduct

On June 5, 2019, the Securities and Exchange Commission (“SEC”) voted to adopt Regulation Best Interest: The Broker-Dealer Standard of Conduct (hereinafter, “Regulation BI”), requiring broker-dealers and their associated...more

Safe and Sound - FINRA and the SEC Issue Guidance on Handling Customer Information and Communications

Recently, the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) separately issued important guidance regarding customer communications surrounding the...more

How Far We Haven't Come: The Revolution Will Not Be Securitized

While SEC FinHub’s new framework announced last week for identifying crypto-securities suggests continued resistance for those using digital assets to access capital markets, an SEC no-action letter issued the same day to...more

Novel Concerns in FINRA's 2019 Risk Monitoring and Examination Priorities Letter

On January 22, 2019, FINRA released its 2019 Annual Risk Monitoring and Examination Priorities Letter (the “Priorities Letter”). Late last year, as part of FINRA360 – the organization’s ongoing improvement initiative – FINRA...more

FINRA Incentivizes Member Firms to Self-Report and Remediate 529 Plan Deficiencies

On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more

FINRA Offers Member Firms Continued Guidance on Cybersecurity

On December 20, 2018, the Financial Industry Regulatory Authority (FINRA) issued a “Report on Selected Cybersecurity Practices” (the “Report”) as part of its ongoing efforts to assist broker-dealer firms in developing...more

Prosecutors and Regulators Deliver Year-End AML Messages to Broker-Dealers

While many of us were winding down the year focused on the December holidays, the U.S. Department of Justice, the SEC, FINRA, and FinCEN were busy delivering a flurry of messages to the broker-dealer industry about AML...more

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