Our recent client alert discusses a recent SEC staff bulletin covering the standards of conduct for broker-dealer and investment adviser conflicts of interest. The staff bulletin includes 13 Q&As categorized into five different flavors relating to identifying, eliminating, mitigating, and disclosing conflicts of interest, as well as related to product…
Our recent client alert discusses a NASAA investor advisory warning about the potential risks of investing in the metaverse. NASAA (the North American Securities Administrators Association) is an organization of state and provincial securities regulators in the United States, Canada, and Mexico.
Our recent client alert discusses the CFTC’s longstanding practice of settling enforcement cases without seeking admissions of wrongdoing (so-called “no-admit/no-deny” settlements). CFTC Commissioner Romero suggests application of a “HEAT” test (Heightened Enforcement Accountability and Transparency), which would encourage CFTC staff to push for admissions of wrongdoing in actions with one or more bad…
Our recent client alert addresses the new SEC “Marketing Rule” for investment advisers and the effect on private fund placement agents. The compliance date is November 4, 2022.
Law360 published some of our recent thoughts on the SEC’s framework for regulating cryptocurrency and DeFi. You can read that article here.
The SEC recently brought fraud charges against Sterlington, Louisiana and its former mayor and separately against Rochester, New York and its former executives and Rochester’s municipal advisors and principals/owners for misleading investors related to their respective bond offerings. At a high level, the SEC alleged (collectively between the two matters):…
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…
Our recent client alert discusses how U.S. financial services regulators are increasingly exploring what the metaverse, augmented reality (AR), and virtual reality (VR) mean for their registrants’ businesses and also for the means and methods of regulating them.
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…
BrokerCheck is the database through which FINRA publishes licensing, registration, and disciplinary history of brokerage industry firms and their personnel. BrokerCheck does not currently specify whether a particular firm is a “Restricted Firm”–one FINRA considers to “pose far higher risks to the public than firms of similar size” based on…