Search Results: Proposed Rulemaking

SEC Examinations Division Publishes 2023 Priorities Letter

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.

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Broker-Dealer Compliance With Revamped Recordkeeping Requirements Begins May 3, 2023; FINRA Publishes Chart of “Most Significant Changes”

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…

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SEC "Gift" to the Industry: Four Market Structure Proposals, 3-2 Votes (In Part), but No Partridge in a Pear Tree

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,…

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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…

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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…

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