On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 10c-1a (the “Securities Lending Rule”), requiring the reporting of certain securities lending transactions. Certain material terms of...more
The SEC Remains in Search of and Is Looking for Finders - Much has been written on the topic of finders and arrangers of securities transactions, including when a person or entity acting as a finder (i.e., someone who...more
The Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 22-14, which proposes to establish new trade reporting requirements for certain over-the-counter (OTC) options transactions. Listed options are...more
In a press release on June 8th, the Commodity Futures Trading Commission (the “CFTC”) published its first release in a series called the “SOFR First Transition Initiative” as a best practice. One goal for this sort of “best...more
On September 16, 2020, the Securities and Exchange Commission adopted amendments to Exchange Act Rule 15c2-11. This rule was last amended about thirty years ago. Rule 15c2-11 prescribes requirements relating to the...more
Since the start of the COVID-19 pandemic in the United States, the U.S. Securities and Exchange Commission (SEC) has increasingly exercised its authority under the Securities Exchange Act of 1934 (the Exchange Act) to suspend...more
• The broader application of Section 871(m) has again been delayed, this time until January 1, 2023 and as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S....more
BROKER-DEALER - SEC Proposes to Amend Quotation Rule for OTC Securities - The Securities and Exchange Commission (SEC) has proposed to amend Rule 15c2-11, which governs the publication and submission of quotations by...more
The staffs of the Division of Trading and Markets (Division) of the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) (collectively, the “Regulators”) published a joint...more
U.S. Financial Industry Developments - FINRA Requests Comment on Financial Technology Innovation in the Broker-Dealer Industry - On July 30, 2018, the Financial Industry Regulatory Authority ("FINRA") published a...more
BROKER-DEALER - Nasdaq Has Proposed a New Rule Change To Modify Its System of Volume-Based Credits - The Nasdaq Stock Market LLC (Nasdaq) has filed with the Securities and Exchange Commission a proposed rule change to...more
SEC Concerns with the “Piggyback” Exception of Rule 15c2-11 - Rule 15c2-11 (“Rule 15c2-11”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), sets forth procedures for the submission and...more
In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more
In this issue: - FINRA Proposes Rule Change that Would Require Reporting OTC Equity Transactions Within 10 Seconds - FINRA Offers Changes to Proposed Rules Governing Markups, Commissions and Fees - CFTC Permits...more
In this issue: - Nallengara to Replace Cross as Corp. Fin. Chief - FINRA Rule Relating to Private Placements of Securities Effective December 3 - Additional Guidance on FINRA’s Suitability Rule - No-Action...more