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 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.
On February 9, 2022, FINRA published its 2022 Report on its Examination and Risk Monitoring Program, identifying key areas of focus for broker-dealer exams this year. While each exam is unique to the firm under FINRA’s microscope, the Report provides a general roadmap of FINRA’s core concerns for 2022. FINRA’s…
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…
SEC Commission Elad Roisman recently spoke about cybersecurity threats and challenges facing the agency’s registrants, including public companies and financial institutions. One source of challenges (our words, not Roisman’s) may come from the government itself—the combination of (1) the lack of clarity on requirements and expectations from the SEC in…