On December 20, 2024, the Securities and Exchange Commission (SEC) issued a final rule amending SEC rules 15c3-3 (the customer protection rule) and 15c3-1 (the net capital rule). The SEC also amended Form X-17A-5 Part II (the...more
On June 5, 2024, the SEC's Division of Examinations (the Division) released a risk alert regarding the examination of broker-dealers. The alert acknowledges the diversity of the broker-dealer population in the marketplace...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
You know what the happiest animal on Earth is? It's a goldfish. Y'know why? It's got a 10-second memory. Be a goldfish. During the pandemic, we have had a lot of lows, as well as a few highs. And that’s just in pop...more
On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement, Corporation Finance, Trading...more
Coming on the heels of the share class initiative, the US Securities and Exchange Commission (SEC) is at the initial stages of another initiative involving concerns about adviser disclosures and conflicts related to bank...more
The New York Fed released a statement of its policies towards managing its open market operations counterparty relationships with private entities, which includes primary dealers in US Treasury securities. Generally, the New...more
On August 18, 2016, the US Securities and Exchange Commission (SEC) approved a new Financial Industry Regulatory Authority (FINRA) rule series intended as a “lite” framework for the registration and regulation of brokers that...more
The Sixth Circuit last week concluded that Morrison, which held that Section 10(b) does not have extraterritorial reach, is inapplicable to Advisers Act Section 10(b). The DC Circuit, on rehearing, reaffirmed its prior...more
In June, the Financial Industry Regulatory Authority updated its interpretations of the Securities and Exchange Commission Rules 15c3-1 (net capital) and 15c3-3 (customer protection). Among other things, FINRA updated its...more
On June 12, Commissioner Kara M. Stein called on the Securities and Exchange Commission to make its net capital requirements for broker dealers more stringent. Commissioner Stein warned that current net capital levels may not...more
The guidance addresses expense arrangements, buy-in procedures, free credit balances, sweep programs, and bulk transfers, among other things. On March 6, the staff of the Securities and Exchange Commission (SEC) issued...more
The Financial Industry Regulatory Authority, Inc. (“FINRA”) issued an order (the “Order”) settling administrative proceedings against a clearing broker-dealer (the “Broker”), regarding various failures to comply with...more
The limited exemption will provide broker-dealers with more time to make necessary operational or systems changes. On October 17, the Securities and Exchange Commission (SEC) issued an order providing a temporary...more