Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our client alert discusses FINRA’s 2023 Report on its Examination and Risk Monitoring Program, which serves as a resource for firms to use to bolster their compliance programs and provides a roadmap of FINRA’s main areas of examination for 2023.
Our client alert discuss the recent SEC amendments to Exchange Act Rule 17a-4 adopting new recordkeeping requirements for broker-dealers. Most notably, the SEC will no longer require broker-dealers to maintain records in “write once, read many” or “WORM” format. Instead, broker-dealers have the option of utilizing a new “audit trail” alternative…
Our client alert discuss recent SEC rulemakings covering proposed new “Regulation Best Execution” (new Exchange Act Rules 1100, 1101, and 1102 establishing a best execution standard and requiring robust policies and procedures for firms engaging in certain conflicted transactions with retail customers); a proposed new “Order Competition Rule” (new Exchange Act Rule 616,…
Our recent client alert discusses the new broker-dealer recordkeeping requirements for broker-dealers.
Law360 published some of our recent thoughts on the SEC’s framework for regulating cryptocurrency and DeFi. You can read that article here.
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 things have headed since the onset of the Covid-19 pandemic (WFH and such), providing firms with the…
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, the SEC has done just that. Rule 15b9-1 currently exempts…
The SEC Division of Examinations recently published its list of priorities for 2022. While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months. Significant focus areas…
The SEC recently proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the existing dealer/trader distinction long-recognized by the SEC. The likely outcome is that most proprietary trading firms will need to register with the SEC as dealers and become members of FINRA or…