News & Analysis as of September 23, 2024

Proposed Amendments

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The Securities Exchance Act is a United States federal statute enacted in 1934 to govern the secondary securities trading market. In addition, the Securities Exchange Act established the Securities and Exchange... more +

The Justice Insiders Podcast: Meet the Securities and Exchange (and Human Resources) Commission

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

Lowenstein Sandler LLP on 3/30/2023

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

Winter Brings Latest Flurry of SEC Rulemaking

Holland & Knight LLP on 12/16/2022

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

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

Goodwin on 8/1/2022

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

SEC Proposes Amendments to Electronic Recordkeeping Requirements

Morgan Lewis on 12/17/2021

While the US Securities and Exchange Commission seeks to modernize electronic recordkeeping requirements in a technology-neutral manner, its proposed amendments are unclear as to the permissible use of the “cloud” or...more

FINRA Proposes Amendments to Customer Account Statement Requirements

Morgan Lewis on 10/8/2021

The US Securities and Exchange Commission (SEC) published for comment on September 30 a proposed rule change by the Financial Industry Regulatory Authority (FINRA) that would amend FINRA Rule 2231—the customer account...more

FINRA Files Rule Change to Extend Implementation Date of Rule 4210 TBA Changes

Morgan Lewis - All Things FinReg on 9/1/2021

FINRA filed a proposed rule change with the US Securities and Exchange Commission (SEC) on August 26, 2021 to delay the effective date of changes to FINRA Rule 4210 that were previously implemented on December 15, 2016. The...more

Corporate & Financial Weekly Digest, Featuring the Articles on LIBOR-Transition Relief and New CFTC Rules for DCOs, Swap Dealers

Katten Muchin Rosenman LLP on 12/23/2019

SEC/CORPORATE - SEC Announces Proposed Amendments to the Definitions of “Accredited Investor” and “Qualified Institutional Buyer” - On December 18, the Securities and Exchange Commission voted to propose amendments...more

Corporate & Financial Weekly Digest, Featuring Articles on SEC's Changes to Rule 14a-8 No-Action Request Process, FINRA's Call for...

Katten Muchin Rosenman LLP on 9/16/2019

SEC/CORPORATE - SEC Staff Announces Changes to Rule 14a-8 No-Action Request Process - On September 6, the staff of the Division of Corporation Finance (the Staff) of the Securities and Exchange Commission announced...more

SEC Proposes Securities Offering Reforms for Business Development Companies and Registered Closed-End Investment Companies

Skadden, Arps, Slate, Meagher & Flom LLP on 4/22/2019

On March 20, 2019, the Securities and Exchange Commission (SEC) voted to propose a series of rule and form amendments, as directed by Congress under the Small Business Credit Availability Act (SBCA) and the Economic Growth,...more

SEC Proposes to Add New Reporting Events to the Municipal Disclosure Rule

Hinshaw & Culbertson LLP on 4/24/2017

On March 15, 2017, the U.S. Securities and Exchange Commission (SEC) published for public comment proposed amendments to the Municipal Disclosure Rule, Rule 15c2-12 under the Securities Exchange Act of 1934. The proposed...more

The SEC Proposes to Shorten the Settlement Cycle for Most Securities Transactions from Three Business Days to Two Business Days

BakerHostetler on 10/12/2016

The Securities and Exchange Commission has proposed to amend Rule 15c6-1 under the Securities Exchange Act of 1934 in order to shorten the standard settlement cycle for most broker-dealer securities transactions from three...more

T+2 is on the Way (Finally)

Parker Poe Adams & Bernstein LLP on 10/11/2016

At long last, the SEC has proposed amendments to its rules that would shorten the standard settlement period for securities transactions from three business days (T+3) to two business days (T+2). The proposal… The...more

Twenty-Three Years Later, One Day Shorter: SEC Proposes T+2 Rule Amendment

Broker-Dealer Compliance + Regulation on 10/3/2016

Twenty-three years after adopting Rule 15c6-1 under the Securities Exchange Act of 1934 (“Exchange Act”) to establish T+3 as the standard settlement cycle for broker-dealer transactions, on September 28, 2016, the SEC...more

FINRA Proposes Exemption From the TAF for Proprietary Trading Firms

Katten Muchin Rosenman LLP on 5/12/2015

On March 25, the Securities and Exchange Commission proposed amendments to Rule 15b9-1 under the Securities Exchange Act of 1934 to require broker-dealers that engage in off-exchange proprietary trading to become members of a...more

Proposed Amendments to SEC Rule 15b9-1 Would Require Most Proprietary Trading Broker-Dealers to Become FINRA Members

Katten Muchin Rosenman LLP on 4/21/2015

Consistent with the increased regulatory scrutiny of proprietary trading firms-and high frequency trading firms in particular—the Securities and Exchange Commission (SEC) recently proposed amendments to SEC Rule 15b9-1 (also...more

Expanding Oversight of Active, Proprietary Trading Firms: SEC Proposes Amendments to Rule 15b9-1

WilmerHale on 4/15/2015

Overview - On March 25, 2015, the Securities and Exchange Commission ("SEC" or "Commission") proposed an amendment to Rule 15b9-1 (the “Proposal”) under the Securities Exchange Act of 1934 ("Exchange Act") that, if...more

Important Regulatory Developments for Proprietary Trading Firms and Broker-Dealers Using Algorithmic Trading Strategies

Foley & Lardner LLP on 4/2/2015

On March 25, 2015, the U.S. Securities and Exchange Commission (SEC) voted unanimously to issue a proposed rule amendment that would significantly narrow the existing exemption that permits many proprietary-trading...more

SEC Proposes to Amend Rule 15b9-1

Katten Muchin Rosenman LLP on 4/1/2015

The Securities and Exchange Commission is proposing to amend Rule 15b9-1 under the Securities Exchange Act of 1934, as amended, to require broker-dealers that engage in off-exchange proprietary trading to become members of a...more

Bridging the Week - March 2015 #5

Katten Muchin Rosenman LLP on 3/31/2015

SEC Proposes FINRA Oversee Certain High-Frequency Trading Firms; FINRA and FIA Issue Best Practice Guidance - The Securities and Exchange Commission proposed changes to an existing rule that, if adopted, would require...more

SEC Rule Change Would Require High-Frequency Traders to Register with FINRA

Proskauer - Corporate Defense and Disputes on 3/30/2015

On March 25, 2015, the SEC proposed an amendment to Rule 15b9-1 that would require high-frequency trading firms to register with FINRA. According to the SEC, the proposed amendment will better align the scope of Rule 15b9-1...more

SEC Adopts Amendments Removing References to Credit Ratings from Exchange Act Rules Relating to Broker-Dealer Financial...

Goodwin on 1/8/2014

The SEC issued Release No. 34-71194 (the “Adopting Release”) adopting amendments under the Securities Exchange Act of 1934 (the “Exchange Act”) that remove references to credit ratings by ratings agencies (including...more

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