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Broker-Dealer Filing Requirements

Seward & Kissel LLP

August 30 Deadline for TIC Form SHL

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Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

K2 Integrity

AML/CFT Rules for Investment Advisers

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On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

Stark & Stark

California & Hawaii Adopt Investment Adviser Representative CE Requirements for 2024

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Investment adviser representative continuing education requirements are critically important. Please read this alert carefully, as investment adviser representative registration may be at risk if you do not follow the...more

Cornerstone Research

SEC Enforcement Activity: Public Companies and Subsidiaries—FY 2023 Executive Summary

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SEC enforcement actions against public companies and subsidiaries rose again in FY 2023, with 91 new actions filed, the third highest of any fiscal year in SEED. Although filings increased, total monetary settlements fell to...more

Cornerstone Research

SEC Enforcement Actions Against Public Companies and Subsidiaries Jump in FY 2023

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Total monetary value of settlements fell to lowest level in last eight fiscal years. The U.S. Securities and Exchange Commission (SEC) filed 91 enforcement actions against public companies and subsidiaries in fiscal year...more

Orrick, Herrington & Sutcliffe LLP

SEC proposes requiring electronic EDGAR filings

On March 22, the SEC proposed amendments intended to “modernize” filing procedures through the use of electronic filings on EDGAR using structured data as appropriate....more

Goodwin

Regulation Best Interest and Form CRS: Spotlight on FINRA’s 2022 Exam and Risk Monitoring Program Report

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This is the first in a series of alerts discussing topics covered by FINRA in its 2022 Examination and Risk Monitoring Program Report (the “Report”). Here we take a look at Regulation Best Interest (“Reg. BI”) and Form CRS,...more

Foley & Lardner LLP

Form PF Changes Ahead – the SEC Keeps Its Focus on Private Fund Advisers

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On January 26, 2022, the Securities and Exchange Commission (“SEC”) voted 3-1 to propose amendments to Form PF. The Form PF, which was initially adopted in 2011 and became effective on June 15, 2012, is a confidential report...more

Akin Gump Strauss Hauer & Feld LLP

SEC Charges 21 Advisers for Form CRS Failures – Impact on Private Fund Managers

On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS. Penalties...more

BCLP

Heads Up! Your Form CRS Grace Period Has Ended: The SEC Drops the Hammer on 27 Firms for Compliance Failures with Form CRS Filing...

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In case you were wondering if you can still push off finalizing your Form CRS filing, posting it on your website and delivering it to clients, the SEC has read your mind and answered loudly: no more! On Monday, the SEC...more

Morrison & Foerster LLP

FINRA Proposes Additional Filing Requirements For Private Placements

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In October 2020, the Financial Industry Regulatory Authority (FINRA) proposed a rule amendment that would expand its filing requirements relating to private placements. Under the proposal, FINRA would amend its Rules 5122...more

White & Case LLP

National Banking and Securities Commission resumes activities during the contingency derived from SARS Cov-2 (COVID-19)

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On July 15, 2020, the National Banking and Securities Commission (the "CNBV") published in the Federal Official Gazette ("DOF") a resolution establishing administrative measures to resume activities during the contingency...more

Nelson Mullins Riley & Scarborough LLP

Form CRS for Investment Advisers, Broker-Dealers, and Dually-Registered Firms Due June 30 Summarized

The U.S. Securities and Exchange Commission (the “SEC”) has adopted Form CRS and related rules under the Investment Advisers Act of 1940 (the “Advisers Act”) and the Securities Exchange Act of 1934 (the “Exchange Act”), in...more

Dechert LLP

Firms Should Move Full Steam Ahead on Regulation Best Interest and Form CRS

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In an April 2, 2020 statement regarding the SEC’s approach to the allocation of resources, oversight and rulemaking in light of the COVID-19 coronavirus, SEC Chairman Jay Clayton discussed Regulation Best Interest (Reg BI)...more

Latham & Watkins LLP

FINRA Issues Guidance and Relief in Relation to COVID-19

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As COVID-19 disruptions unfold, FINRA has granted temporary relief regarding alternate working arrangements for broker-dealer employees. On March 9, 2020, the Financial Industry Regulatory Authority, Inc. (FINRA) issued...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on SEC Approves Amendments to FINRA New Issue Rules, CFTC Announces...

SEC/CORPORATE - SEC Approves Amended Rule Change to FINRA Rule 5110 - On December 23, 2019, the Securities and Exchange Commission approved the Financial Industry Regulatory Authority’s (FINRA) proposed amendments to...more

Eversheds Sutherland (US) LLP

Videocast: Form CRS delivery obligations

Beginning June 2020, the SEC will require most broker-dealers and investment advisers to file and deliver a Form CRS to new, prospective and existing customers and clients. As firms begin to prepare Form CRS, much attention...more

Vedder Price

The New Standards for Investor Protection: An Analysis of Regulation Best Interest, Form CRS and Two Interpretations of the US...

Vedder Price on

On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted three to one to approve a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

A&O Shearman

FINRA Proposes Substantive and Organizational Amendments to Corporate Financing Rule

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On April 25, 2019, the Financial Industry Regulatory Authority, Inc. (“FINRA”) filed proposed amendments to FINRA Rule 5110 (“FINRA Rule 5110” or “the Rule”), commonly referred to as the “Corporate Financing Rule”, with the...more

Ballard Spahr LLP

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

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Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Kelley Drye & Warren LLP

FINRA Proposes Changes for New Membership Applications and Continuing Membership Applications

Last week FINRA issued a 51 page (with 85 Footnotes) Regulatory Notice (#18-23) which proposes major and far reaching changes to the rules and procedures for New Membership Applications and Continuing Membership Applications....more

Carlton Fields

Expect Focus - Volume II, June 2018

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New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 8, Issue 4

FINRA’s Proposed Amendments to the Corporate Financing Rules – Impact on Structured Notes - In April 2017, FINRA released a set of significant proposed amendments to its Rule 5110, known as the “Corporate Financing Rule.” ...more

Stinson - Corporate & Securities Law Blog

SEC Simplifies Filing of Broker-Dealer Annual Reports on EDGAR

The SEC has previously provided guidance on the filing of annual and supplemental reports required under Rule 17a-5 or Rule 17a-12 by broker-dealers or over-the-counter derivatives dealers on the SEC EDGAR system. However,...more

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