Payment for Order Flow (PFOF) and Gamification: Your Questions Answered
Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion
Investment Management and Private Funds Roundtable – June 2020
Videocast: Asset management regulation in 2020 videocast series – FinTech initiatives
Videocast: Asset management regulation in 2020 videocast series – Fiduciary investment advice: The patchwork emerges
Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
Videocast: Asset management regulation in 2020 videocast series – Complying with new SEC rules for broker-dealers
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Regulation Best Interest Videocast Series: Establishing An Investment Platform Post-Regulation BI
Investment Management Update - Focus on Data Privacy and Cybersecurity
On June 27, FINRA issued Regulatory Notice 24-09 that discussed the implications to broker-dealers in their use of artificial intelligence (AI), including large language models (LLMs) and other generative AI tools. Although...more
FINRA’s guidance sheds further light on the new rule, which will permit firms to elect “non-branch” designation for a private residence where an associated person conducts specified supervisory activities....more
As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
On October 30, 2023, the Securities and Exchange Commission issued an order (the “Order”) that grants exemptive relief under Rule 15c2-11 under the Securities Exchange Act of 1934 to brokers and dealers that publish...more
On September 27, 2023, facing the prospect of a lapse of appropriations, the staff of the Securities and Exchange Commission’s Division of Corporation Finance published a summary of the anticipated impact on its operations of...more
Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
Regulatory Developments - CFPB Issues Guidance on Investigation Practices by Consumer Reporting Agencies - On November 10, the CFPB issued a Consumer Financial Protection Circular (Circular) affirming that consumer...more
FINRA recently published Regulatory Notice 22-23, providing guidance regarding firm and representative succession planning, including relevant FINRA rules and administrative processes and questions firms can consider when...more
Regulatory Developments - FINRA Requests Comment on Its Machine-Readable Rulebook Initiative - On October 21, FINRA released a special notice requesting comment on the launch of its MRR initiative. The MRR is designed...more
FINRA’s recent overhaul of its Sanction Guidelines is the largest and most significant in two, if not three, decades. It would be quite the understatement to say that the time had come for FINRA to make a much-needed change...more
On September 27, 2022, 15 broker-dealers and one investment adviser agreed to pay more than $1.8 billion in total civil penalties to the US Securities and Exchange Commission (SEC), and, for those same companies or affiliates...more
Understand What’s Happening in the Financial Industry Regulatory World With Commentary and Updates From Bracewell’s Experienced FINRA Team - We are pleased to introduce the inaugural issue of Bracewell’s FINRA Facts and...more
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
On March 17, the Financial Industry Regulatory Authority (FINRA) issued a notice, clarifying when chief compliance officers (CCOs) will face liability as supervisors under FINRA Rule 3110. Under Rule 3110, member firms are...more
The regular “Weekly Update” email from the Financial Industry Regulatory Authority (“FINRA”) had an eye-catching warning February 16, urging broker-dealer member firms to heed the “Shields Up” cyber threat warning from the...more
After extensive retrospective review of FINRA Rule 4370, which covers member firm business continuity plan (“BCP”) requirements during times of business disruption (such as the COVID-19 Pandemic), FINRA issued its...more
After a period of astounding growth in the special purpose acquisition company (SPAC) market, FINRA recently joined the SEC in announcing further scrutiny of broker-dealers and their affiliates involved in SPAC offerings,...more
The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more
The focus on quantifying LIBOR exposure and related disclosure requirements may be a ‘red herring.’ The real issues are (i) whether the LIBOR transition is merely an excuse to change the effective interest rates of financial...more