Our recent client alert discusses the SEC’s “Reg Flex” agenda for rulemaking, which provides a glimpse into how the agency will prioritize its resources over the coming six months from a policy and rulemaking standpoint.
Our recent client alert discusses the SEC’s “Reg Flex” agenda for rulemaking, which provides a glimpse into how the agency will prioritize its resources over the coming six months from a policy and rulemaking standpoint.
It came as no surprise that FINRA’s 2022 Examination and Risk Monitoring Program Report highlighted communications with the public as a continued area of focus. The primary theme across this focus area relates to the sufficiency of internal processes, procedures, and controls. As FINRA has done with other areas, the…
Securities law enforcement entered the metaverse recently in the form of an emergency cease and desist order issued by the Texas State Securities Board against individuals and a company using NFTs to finance multiple metaverse casinos. Much like Wyatt Earp busting into the O.K. Corral, this one gets interesting. The…
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…
Our recent client alert discusses President Biden’s Executive Order Ensuring Responsible Development of Digital Assets.
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.
Here is a link to our client alert discussing the SEC proposed rulemaking in this area.
Here is a link to our client alert addressing the SEC’s proposed change to the “exchange” definition, including introduction of the new term “communication protocol system.” There were zero references to crypto, blockchain, DeFi, or distributed ledger technology in the 654-page proposal. Nevertheless, the proposal makes clear that it applies…
On January 26, 2022, SEC Chairman Gary Gensler issued a brief statement noting the agency’s efforts to address the market volatility in January 2021 and beyond. The statement referenced the SEC staff report on volatility and market structure conditions and a request for comment related to digital engagement practices or…