FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory responsibilities delegated to them. FINRA recognizes that compliance and supervision are distinct roles that carry different obligations. FINRA has said that…
Our recent client alert discusses President Biden’s Executive Order Ensuring Responsible Development of Digital Assets.
On March 15, 2022, SEC Commissioner Allison Herren Lee announced she will not seek a second term once her current term expires in June of this year. The departure of Commissioner Lee, a Democrat-appointee, follows the January 2022 departure of Republic-appointee Commissioner Elad Roisman and sets the table for paired…
Our recent client alert discusses the SEC’s proposed rules for public company cybersecurity disclosures. The proposed rules are the latest step in the SEC’s broad approach to cybersecurity matters such as risk management, corporate governance and strategy, incident reporting and public disclosure.
FINRA recently reminded firms of their obligation to execute marketable customer orders fully and promptly. While this seems fairly routine, what’s notable about the reminder is that “prompt” doesn’t necessarily mean what it used to. FINRA Rule 5310 (Best Execution and Interpositioning) requires a firm to “make every effort to…
Our recent client alert distills FINRA’s findings on Reg. BI and Form CRS so you don’t need to read it all yourself.
On February 15, 2022, the SEC announced settlements with 12 broker-dealers and investment advisers for failing to satisfy their Form CRS obligations. These settlements come on the heels of 27 settlements last year for similar violations. While all settlements included both a failure to timely file and deliver relationship summaries,…
Our recent client alert discusses recent FINRA rule changes to provide broker-dealers with additional resources to prevent elder financial fraud.
Our recent client alert addresses recent SEC proposed rulemaking that would radically change private fund regulation.
Our recent client alert addresses the SEC’s campaign to overhaul the agency’s expectations around cybersecurity and cyber incident reporting for the financial services industry and corporate America generally.