Search Results: Proposed Rulemaking

FINRA Proposes Remote Inspection Pilot Program

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…

Read More

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

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…

Read More

SEC Publishes Spring Rulemaking Agenda: Torrid Pace Continues; Crypto Framework Noticeably Absent

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.

Read More

SEC Proposes ESG Disclosure Rules for Investment Advisers and Investment Companies

Our recent client alert discusses the package of new rules the SEC recently proposed to address and enhance investor disclosure practices, and related policies and procedures, regarding ESG investment considerations and objectives by investment advisers to registered investment companies and private funds and other clients.

Read More

SEC Extends Comment Periods for Recent Rulemakings. Applaud the Move or Criticize the Need To Take Action At All?

On May 9, 2022, the SEC extended the comment periods for proposed rulemaking on climate-related disclosures and reopened the comment period for proposed rulemaking relating to private funds and what it means to be an “exchange” under Exchange Act Rule 3b-16.  Each of these proposals originally provided 30 days for…

Read More

SEC Examinations Division Publishes 2022 Priorities

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…

Read More

Ding, Dong! The Dealer/Trader Distinction is Dead. HFTs and DEX AMMs Should Take Notice

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…

Read More