Videocast: Asset management regulation in 2020 videocast series – The ADV season
Videocast: Asset management regulation in 2020 videocast series – Complying with new SEC rules for broker-dealers
Videocast: Form CRS delivery obligations
Regulation Best Interest Videocast Series: Special Challenges For Dual Registrants
On August 5, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) against a member firm for three alleged violations related to the failure to maintain policies and procedures and supervisory systems in compliance...more
On January 9, 2024, FINRA published its 2024 Annual Regulatory Oversight Report (the “Report”). FINRA publishes the Report as a way to provide its broker-dealer members with insight into findings from FINRA’s Member...more
FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more
On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more
Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
On January 10, 2023, FINRA issued its 2023 Report on FINRA’s Examination and Risk Monitoring Program to provide “insight into findings from the recent oversight activities of FINRA’s Member Supervision, Market Regulation and...more
FINRA recently hosted a conference call with its smaller members covering Regulation Best Interest and Form CRS compliance. FINRA’s resounding message was that there is “no one-size-fits all” approach to Reg. BI...more
BrokerCheck is the database through which FINRA publishes licensing, registration, and disciplinary history of brokerage industry firms and their personnel. BrokerCheck does not currently specify whether a particular firm is...more
The SEC Division of Examinations recently published its list of priorities for 2022. While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the...more
On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more
A common phrase to abide by in the New Year is “out with the old, in with the new.” FINRA’s 2022 Report on its Examination and Risk Monitoring Program (the “Report”), however, contains a combination of old and new priorities....more
Over the last couple of decades, the securities self-regulatory organization FINRA (f/k/a NASD) informs its membership each year of what compliance risks are noted by its examination program. Those are risks firms should...more
F. Scott Fitzgerald said “There are only the pursued, the pursuing, the busy, and the tired.” FINRA may be all of these in 2022, as FINRA CEO Robert Cook announced FINRA’s laundry list of priorities during a SIFMA Q&A last...more
Putting Teeth on Reg BI (to take a bite out of complex products sales), Protecting Seniors (from romance scams, affinity frauds, and rogue POAs), Scrutinizing Bank-Based Reps, DBAs, and Remote Supervision, and the beginning...more
The no-action relief applies to family offices with at least US$50 million in total assets (Institutional Family Offices) and requires broker-dealers seeking to rely on the relief to establish and maintain specific additional...more
President-Elect Joe Biden is quickly learning that the line of people seeking regulatory reform in the wake of the Trump administration's regulatory free-for-all is getting longer all the time. At the front of the line is...more
The U.S. Securities and Exchange Commission (SEC) hosted a virtual roundtable in late October to discuss the Regulation Best Interest (Reg BI) and Form CRS. With a few months of observations from examinations since the June...more
In a public statement issued on June 15, 2020, U.S. Securities and Exchange Commission (SEC) Chairman Clayton confirmed the June 30, 2020, deadlines for compliance with Regulation Best Interest (Reg. BI) and the Form CRS...more
Firms must demonstrate a “good faith effort” to comply. Last month, SEC Chairman Clayton issued a public statement communicating that firms should not expect a delay of the June 30, 2020 compliance date for Regulation Best...more
The June 30 deadline for compliance with Regulation Best Interest [1] and Form CRS [2] presents new compliance obligations for broker-dealers and investment advisers engaging in a retail business. In anticipation of this...more
While the world at large shelters in place due to COVID-19 legal and regulatory activity of digital asset and the blockchain world is hopping. ...more
Recently, the U.S. Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide broker-dealers with guidance on examinations regarding regulation Best...more
What You Need To Know; • The Form CRS must be filed with the SEC by June 30, 2020, at the latest. • All investment advisers, broker-dealers, or dual registrants that service retail investors may now file the Form CRS with the...more
On April 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published two Risk Alerts for Regulation BI and the corresponding Customer Relationship Summary Form (Form CRS). The Risk Alerts outline the...more
This week OCIE issued twin alerts relating to the upcoming implementation of Reg BI. A lot of the statements are nothing new – brief repetitions of the Regulation, the four obligations, etc. None of that should be new...more