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.
On March 15, 2022, SEC Commissioner Allison Herren Lee announced she will not seek a second term once her current term expires in June of this year. The departure of Commissioner Lee, a Democrat-appointee, follows the January 2022 departure of Republic-appointee Commissioner Elad Roisman and sets the table for paired…
Our recent client alert discusses the SEC’s proposed rules for public company cybersecurity disclosures. The proposed rules are the latest step in the SEC’s broad approach to cybersecurity matters such as risk management, corporate governance and strategy, incident reporting and public disclosure.
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 recent SEC proposed rulemaking that would radically change private fund regulation.
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…