News & Analysis as of

Financial Industry Regulatory Authority (FINRA) Enforcement Guidance

BCLP

Observations from a Review of FINRA’s 2021 Sanction Guidelines

BCLP on

Key Takeaways: ..FINRA released its most recent Sanctions Guideline, effective immediately, on October 20, 2021. A link to that document can be found here. ..The key change in the 2021 Sanctions Guideline is a new...more

BCLP

The Song Remains the Same - FINRA’s Riff on High-Risk Brokers and Firms

BCLP on

Key Takeaways: ..On September 28, 2021, FINRA released Regulatory Notice 21-34 which introduces additional new rules aimed at addressing high risk or “recidivist” brokers and the member firms that hire them.  ..Under...more

Jones Day

FINRA Clarifies When Credit for Extraordinary Cooperation Will Be Awarded in Investigations

Jones Day on

The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more

A&O Shearman

FINRA Releases New Guidance On Extraordinary Cooperation Credit

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On July 11, 2019, FINRA provided additional guidance on obtaining extraordinary cooperation credit to supplement its prior enforcement guidance. FINRA Regulatory Notice 19-23, FINRA Investigations: FINRA Supplements Prior...more

Katten Muchin Rosenman LLP

Bridging the Week - March 2019 #2

Unexpectedly, the Commodity Futures Trading Commission announced a new initiative to encourage non-registrants to self-report foreign corrupt practices, which it claimed might also constitute violations of laws and rules it...more

Orrick - Employment Law and Litigation

NYCCHR’s Enforcement Guidance on NYC Credit Check Law: Answers and New Questions

On September 2, 2015, the New York City Commission on Human Rights (NYCCHR or Commission) issued Enforcement Guidance (Guidance) on the New York City Stop Credit Discrimination in Employment Act (SCDEA), which took effect on...more

Seyfarth Shaw LLP

New York City Offers Guidance for Employers on the Use of Credit History in Employment Decisions

Seyfarth Shaw LLP on

As we blogged about previously, Mayor Bill De Blasio signed into law the Stop Credit Discrimination in Employment Act (“SCDEA”) in May. The SCDEA went into effect on September 3, 2015 and it prohibits employers from using an...more

Morgan Lewis

NYC Commission on Human Rights Releases Interpretive Enforcement Guide for the SCDEA

Morgan Lewis on

The Commission’s guide outlines narrow interpretation and recordkeeping requirements for employers seeking exemptions to the SCDEA, as well as guidance on enforcement and penalties for SCDEA violations....more

Epstein Becker & Green

NYC Commission on Human Rights Issues Enforcement Guidance for Newly Effective Credit Check Law

Epstein Becker & Green on

On September 3, 2015, the amendment to the New York City Human Rights Law (“NYCHRL”) prohibiting the use of credit checks in employment (“Credit Check Law”) became effective. On the same day, the New York City Commission on...more

BakerHostetler

Regulators Issue Joint Guidance on Business Continuity Planning

BakerHostetler on

Last Friday, the SEC, FINRA and CFTC issued joint guidance (Joint Guidance) on the "best practices and lessons learned" from their review of the business continuity and disaster recovery plans of firms as a result of the...more

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