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Recordkeeping Requirements Brokers

The Volkov Law Group

Pain in the App: Messaging Apps Lead to Large SEC Enforcement Actions

The Volkov Law Group on

On September 29, 2023, the U.S. Securities and Exchange Commission charged several firms with recordkeeping failures. These recordkeeping failures relate to pervasive and longstanding off-channel communications.  Generally,...more

Foley & Lardner LLP

SEC Proposed Safeguarding Rule

Foley & Lardner LLP on

On February 15th 2023, the Securities and Exchange Commission (the “SEC”, or the “Commission”) proposed a new safeguarding rule. Comments must be received by the SEC on or before 60 days after the rule’s publication in the...more

Mintz - Employment Viewpoints

The Department of Labor’s 2016 Final Fiduciary and Conflict of Interest Regulations: Amendments to Prohibited Transaction...

This post continues our examination of the Department of Labor’s suite of final fiduciary and conflict of interest regulations. Our previous posts discussed the newly expanded definition of “investment advice fiduciary”; the...more

Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

Broker-Dealer Compliance + Regulation

FINRA Proposes Rules to Help Avoid Financial Exploitation of Seniors

Avoiding financial exploitation of older investors has been on our regulators’ radar screens for several years. With new rules proposed in October 2015, FINRA seeks to make investing safer for seniors and other vulnerable...more

BakerHostetler

An Instant Message from the CFTC: Preserve Communications – Enforcement Is Up!

BakerHostetler on

The U.S. Commodity Futures Trading Commission (“CFTC”) released its annual enforcement review for 2014. The results—an impressive list of enforcement action success coupled with record fines. There were over $3.27 billion in...more

McNees Wallace & Nurick LLC

Pennsylvania Supreme Court Upholds IFTA Liability Against Brokerage Company with Inadequate Records

On April 24, 2013, the Pennsylvania Supreme Court affirmed, without opinion, the Commonwealth Court’s decision in R & R Express v. Commonwealth, 37 A.3d 46 (Pa. Cmwlth. 2012). In R & R Express, a three-judge panel of the...more

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