News & Analysis as of

Securities and Exchange Commission (SEC) Proposed Amendments Broker-Dealer

Eversheds Sutherland (US) LLP

FINRA proposes revisions to SEC-mandated heightened supervision plans for off-channel communications

On May 8, the Financial Industry Regulatory Authority (FINRA) published a blog announcing that it intends to modify the heightened supervision plans (HSPs) imposed as part of certain broker-dealers’ settlements with the US...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - December 2024

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Perkins Coie

SEC Proposes To Amend Broker-Dealer Customer Protection Rule Reserve Account Calculation Requirements

Perkins Coie on

The U.S. Securities and Exchange Commission (SEC) proposed to amend Exchange Act Rule 15c3-3 (the Customer Protection Rule)[1] on July 12, 2023. If adopted, the proposed amendments would increase the frequency with which...more

Goodwin

Financial Institution Diversity Voluntary Self-Assessments: Due September 30

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Financial Institution Diversity Voluntary Self-Assessments: Due September 30 - On July 13, the FDIC issued a financial institution letter announcing that FDIC-supervised financial institutions are encouraged to...more

Perkins Coie

With Specific Focus on Crypto, SEC Revisits Proposed “Exchange” Definition Changes

Perkins Coie on

The U.S. Securities and Exchange Commission (the SEC or the Commission) voted on Friday, April 14, 2023, to reopen the comment period for previously proposed amendments to Rule 3b-16 under the Exchange Act of 1934 (the...more

WilmerHale

SEC Proposes to Expand Reg SCI

WilmerHale on

The Securities and Exchange Commission (SEC) proposes to amend Regulation Systems Compliance and Integrity (Reg SCI) to update and expand the regulatory oversight of the core technology of the U.S. securities markets.1 The...more

Seward & Kissel LLP

SEC Staff Issue Risk Alert on Safeguarding Customer Records and Information at Branch Offices

Seward & Kissel LLP on

Who may be interested: Registered Investment Advisers, Broker-Dealers. Quick Take: The SEC’s Division of Examinations staff (Staff) recently issued a risk alert (Alert) highlighting deficiencies and trends that the Staff...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

FINRA Re-Proposes Work-From-Home Supervisory Locations

Goodwin on

Firms would be able to treat private residences as non-branch offices instead of OSJs under certain circumstances. FINRA hopes to align its supervisory rules with current work-from-home practices....more

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

Lowenstein Sandler LLP on

On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

WilmerHale

SEC Proposes Changes to Reg S-P to Impose New Cybersecurity-Related Requirements on Covered Institutions

WilmerHale on

On March 15, 2023, the Securities and Exchange Commission (SEC) announced proposed changes to Regulation S-P (“Reg S-P”) that would impose new cybersecurity incident response requirements on broker-dealers, investment...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

Holland & Knight LLP on

The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Seward & Kissel LLP

SEC Proposes Amendments to Regulation S-P

Seward & Kissel LLP on

...Quick Take: The SEC proposed amendments to Regulation S-P which would establish minimum standards under Federal law requiring registered investment advisers, investment companies, broker-dealers and transfer agents...more

Sullivan & Worcester

SEC’s Proposed Changes to Regulation S-P Would Overhaul Records and Information Requirements of Covered Institutions

Sullivan & Worcester on

On March 15, 2023, the United States Securities and Exchange Commission (“SEC”) proposed amendments to Regulation S-P that, if finalized, would place additional burdens on covered institutions when it comes to handling...more

Morrison & Foerster LLP

New SEC Rules and Amendments Shorten the Standard Securities Transaction Settlement Cycle to T+1

On February 15, 2023, the U.S. Securities and Exchange Commission (SEC) adopted rules and amendments to shorten the standard settlement cycle for transactions in most securities from two business days after the trade date...more

WilmerHale

SEC Holiday Reading List: Four Rule Proposals That Would Overhaul Market Structure and How Retail Orders Are Executed

WilmerHale on

On December 14, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard...more

Holland & Knight LLP

Winter Brings Latest Flurry of SEC Rulemaking

Holland & Knight LLP on

We here at SECond Opinions pride ourselves on staying current on all things SEC. But how about when in a single day, the SEC finalizes one rule and proposes four others (totaling 1,656 pages!) that could drastically change...more

Davis Wright Tremaine LLP

SEC Issues Four Proposals with Potentially Broad Ramifications on Equity Market Structure

The Securities and Exchange Commission ("SEC" or the "Commission") issued four sweeping proposals on December 14, 2022, covering a broad range of market structure and regulatory issues facing the equities markets. The four...more

Goodwin

CFPB Publishes Circular Confirming Failure to Safeguard Consumer Data Could Be Unfair in Violation of CFPA

Goodwin on

In This Issue: ..The Consumer Financial Protection Bureau (CFPB) published a Consumer Financial Protection Circular 2022-04 (Circular) in relation to safeguarding consumer data under the Consumer Financial Protection Act...more

Goodwin

FINRA Proposes Remote Inspection Pilot Program

Goodwin on

​​​​​​​FINRA recently proposed amendments to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year pilot program (Pilot Program) to allow member firms to conduct remote branch office inspections.  In a nod to where...more

Goodwin

SEC Proposes Amendments to Exchange Act Rule 15b9-1 - Is FINRA Taking Over the Lease at 100 F Street NE?

Goodwin on

Back in April 2022, we wrote about the SEC killing the Dealer/Trader distinction. We also noted then that it would come as no surprise to see the SEC re-propose amendments to Exchange Act Rule 15b9-1. Just a few months later,...more

Fenwick & West LLP

SEC Proposes Rules Requiring Disclosure of Short Positions and Activities by Certain Managers

Fenwick & West LLP on

On February 25, 2022, the U.S. Securities and Exchange Commission issued a proposal—Short Position and Short Activity Reporting by Institutional Investment Managers (the Proposal)—that would require certain institutional...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes New Cybersecurity Risk Management Rules for Registered Investment Advisers and Funds

On Wednesday, the Securities and Exchange Commission announced proposed new cybersecurity risk management rules and amendments for investment advisers and investment companies. The proposed rules are designed to address...more

Foley & Lardner LLP

Form PF Changes Ahead – the SEC Keeps Its Focus on Private Fund Advisers

Foley & Lardner LLP on

On January 26, 2022, the Securities and Exchange Commission (“SEC”) voted 3-1 to propose amendments to Form PF. The Form PF, which was initially adopted in 2011 and became effective on June 15, 2012, is a confidential report...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

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