News & Analysis as of

Proposed Regulation Comment Period Broker-Dealer

Faegre Drinker Biddle & Reath LLP

Investors Versus Machines: The SEC Cracks Down on AI, Robo-Advisors and Potential Conflicts of Interest

We are probably still years away from Wall Street being overrun by actual robots. Nonetheless, artificial intelligence (AI) tools are divisively integrating into all aspects of society—from the classroom to the courtroom....more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - April 2023

SEC Rules and Amendments - Liquidity Rule Amendments: Interval Funds to the Rescue? On November 2, 2022, the Securities and Exchange Commission (SEC) voted to propose significant amendments to Rule 22e-4 under the...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

WilmerHale

SEC Proposes Significant New Regulatory Obligations for Communication Protocol Systems and Government Securities ATSs

WilmerHale on

The Securities and Exchange Commission (SEC) proposed significant changes to the regulation of securities trading systems that use non-firm trading interest and alternative trading systems (ATSs) that trade government...more

Eversheds Sutherland (US) LLP

FINRA delays implementation of amendments to FINRA Rule 4210 to October 26, 2021

The Financial Industry Regulatory Authority, Inc. (FINRA) filed a proposed rule change with the Securities and Exchange Commission (SEC) on December 22, 2020, to once more delay the implementation of amendments to FINRA Rule...more

Goodwin

Financial Services Weekly News: FDIC Releases Guide To Connect Fintechs With Banks

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more

McGuireWoods LLP

Recent New Jersey Rule Proposal Progresses State Efforts to Impose Fiduciary Duties on Brokers

McGuireWoods LLP on

On April 15, the New Jersey Bureau of Securities (the “Bureau”) issued a rule proposal to establish a uniform fiduciary duty standard applicable to investment advisers, brokers-dealers and their registered representatives and...more

Kilpatrick

Clarifying the Single Issuer Exemption for Broker-Dealers

Kilpatrick on

On September 20th, the SEC released a proposed rule amending Rule 17a-5 of the Securities Exchange Act of 1934, as amended (“Exchange Act”).[1] Under Rule 17a-5(d)(1)(i)(C) of the Exchange Act, broker-dealers registered with...more

Katten Muchin Rosenman LLP

SEC Proposes Conduct Standards for Investment Advisers

On April 18, concurrently with its publication for comment of a proposed fiduciary rule for brokers,1 the Securities and Exchange Commission (SEC) took several actions that broadly implicate investment advisers....more

A&O Shearman

Raising the Bar? SEC Proposes Broker-Dealer Standard of Care and Guidance on Investment Advisers’ Fiduciary Standard

A&O Shearman on

On April 18, 2018, the U.S. Securities and Exchange Commission (“SEC”) took the long-awaited step of proposing rules, interpretations and guidance (the “Proposed Rules”) that would seek to enhance and clarify the standards of...more

Dechert LLP

SEC Proposes Rules Addressing Broker-Dealer and Investment Adviser Standards of Conduct

Dechert LLP on

On April 18, 2018, the U.S. Securities and Exchange Commission (SEC) voted 4-1 to propose a package of rules and interpretations (Proposals) intended to improve the retail investor experience and to provide greater clarity...more

A&O Shearman

FINRA Proposes Revisions to Gifts, Gratuities and Non-Cash Compensation Rules

A&O Shearman on

On August 5, 2016, FINRA in Regulatory-Notice 16–29 proposed revisions to its regulation of broker-dealer gifts, entertainment and non-cash compensation (the “proposal”) and requested comment to the same. The comment period...more

Allen Matkins

The DBO Wants Your Social Security Number, But Is It Legal?

Allen Matkins on

Readers will recall that last year the California legislature created a statutory exemption for finders from the California’s registration requirement for broker-dealers (Chap. 743, Stats. 2015). That exemption, codified at...more

Dorsey & Whitney LLP

The SEC Proposes Rules to Address Investment Advisor and Broker-Dealer Incentive Based Compensation

Dorsey & Whitney LLP on

The SEC recently released a proposed rule pursuant to Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) with respect to the implementation of incentive-based compensation arrangements...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Extends Comment Period on Proposed FINRA Pay-to-Play Rule "

On March 29, 2016, the Securities and Exchange Commission (SEC) filed an order instituting proceedings (the Order) intended to determine whether to approve or disapprove Financial Industry Regulatory Authority (FINRA)...more

Katten Muchin Rosenman LLP

Revised Pay-to-Play Rules

The Securities and Exchange Commission is seeking comments on a revised proposal recently filed by the Financial Industry Regulatory Authority to establish “pay-to-play” and related rules regulating the activities of FINRA...more

Eversheds Sutherland (US) LLP

Hailing a CAB – Does FINRA’s Proposed Capital Acquisition Broker Rule Set Get Private Fund Sponsors to Their Desired Destination?

For many years, the private fund industry and the securities bar have called for a limited rule set to govern broker-dealers solely engaged in raising capital for private funds or other issuers of unregistered securities or...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

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