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SEC Brings Charges for Failure to File Forms 13F (Investment Manager Share Positions) and 13H (Large Trader Registration)

The SEC’s September 17, 2024, actions signal its commitment to penalize non-compliance, while encouraging market participants to self-report violations. On September 17, 2024, the US Securities and Exchange Commission...more

SEC Outlines 2024 Examination Priorities

The priorities highlight emerging and core risk areas for investment advisers, broker-dealers, and other entities, including cybersecurity and crypto assets. On October 16, 2023, the Securities and Exchange Commission’s...more

Illinois Considering Crypto Licensing

A legislative initiative in Illinois would establish licensing and consumer protection requirements for digital asset businesses serving consumers in the state. On February 21, 2023, the Illinois Department of Financial...more

When Are CCOs on the Hook? FINRA Offers Guidance on CCO Liability

Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. On March 17, 2022, the...more

SEC Issues Alert on Compliance Risks Related to COVID-19

As COVID-19 continues to disrupt routine operations, OCIE reminds broker-dealers and investment advisers of their ongoing obligations. On August 12, 2020, the US Securities and Exchange Commission (SEC) Office of...more

The Yellow Brick Road for Consumer Tokens: The Path to SEC and CFTC Compliance - An Update

Developing a framework for consumer tokens - With the rapid growth in the development of blockchain technology, virtual currencies and token sales (sometimes referred to as initial coin offerings, or ICOs), token...more

FINRA Publishes Its 2019 Report on Examination Findings and Observations

The Annual Report provides transparency on FINRA’s recent examination findings and focus for the coming year. On October 16, 2019, the Financial Industry Regulatory Authority (FINRA) published its annual Report on...more

SEC Announces Customer Protection Rule Initiative

Broker-dealers with historical or ongoing instances of non-compliance with the SEC’s Customer Protection Rule are encouraged to self-report by November 1, 2016. On June 23, 2016, the Securities and Exchange...more

SEC Announces Compliance Date for Pay-to-Play Rule

Despite the July 31, 2015 compliance date, the SEC will not enforce the third-party solicitation ban until corresponding FINRA/MSRB Rules take effect. On June 25, 2015, the Securities and Exchange Commission (SEC)...more

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

A summary of a private equity firm’s compliance obligations, a discussion of notable developments in 2014 and highlights of the SEC’s examination priorities for 2015. US federal laws and regulations, as well as the...more

SEC Proposed Rules: Recordkeeping and Reporting for SBSDs, MSBSPs and BDs; Capital Rules for Certain SBSDs

The SEC has proposed recordkeeping and reporting rules and capital charges for security-based swap dealers based on the current broker-dealer reporting and recordkeeping regime. Market participants in the derivatives...more

SEC Approves Significant Amendments to FINRA Rules 5110 and 5121

The amendments simplify and refine the scope of FINRA’s corporate financing and conflict of interest rules in several important respects. The Securities and Exchange Commission (SEC) recently approved two proposals...more

Recent SEC Enforcement Actions Put Spotlight On Prohibited Short Selling

Recent SEC enforcement actions demonstrate the SEC’s increased focus on violations of Rule 105 of Regulation M. On September 17, 2013, the Securities and Exchange Commission (the SEC) announced enforcement actions...more

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