On November 17, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued no-action relief permitting a registered representative-owned personal services entity (“PSE”) to receive transaction-based compensation (“TBC”) without registering as a broker-dealer (“BD”) pursuant to Section 15(b) of the Securities Exchange Act of
Joshea Mark
SEC Division of Examinations Announces 2026 Exam Priorities
Under new SEC leadership, the Division’s 2026 Examination Priorities reflect a modified approach, following a reevaluation of the Division’s risk-based priorities, and a renewed focus on several traditional risk areas (including Regulation Best Interest, adherence to fiduciary standards of conduct, complex products and the Broker-Dealer Financial Responsibility Rules) as well as continued attention to emerging …
SEC Commissioner Uyeda Provides Update on Implementation of U.S. Treasury Clearing Rules
By Joshea Mark on
At the recent 2025 U.S. Treasury Market Conference, Securities and Exchange Commission (“SEC”) Commissioner Mark T. Uyeda provided an update on the implementation of the Treasury Clearing Rules. In his remarks, Commissioner Uyeda said the SEC is focused on resolving regulatory ambiguities and addressing unforeseen issues associated with the implementation of the rules. He noted …
SEC Chair Outlines “Project Crypto” — A Framework for Digital Asset Regulation
By Steffen Hemmerich, Joshea Mark & Stephen Vogt on
Posted in Digital Assets, SEC News
- Digital Commodities: crypto assets
FINRA Initiates Targeted Review of Practices Relating to Small-Capitalization Offerings
By Steffen Hemmerich, Joshea Mark & Stephen Vogt on
Posted in FINRA
FINRA has commenced a targeted review of member firm practices relating to public and private offerings undertaken by small-cap, exchange-listed issuers with business operations in foreign jurisdictions, including China (collectively, “small-cap offerings”). The review focuses on (i) firms that have participated in multiple small-cap offerings as an underwriter, bookrunner, syndicate member, selling group member, or…
FINRA Advances Regulatory Mission Through Artificial Intelligence
By Steffen Hemmerich, Joshea Mark & Stephen Vogt on
FINRA’s President and Chief Executive Officer, Robert Cook, recently published a blog post describing FINRA’s ongoing efforts to integrate artificial intelligence (“AI”), including generative AI (“GenAI”), into its regulatory program and engage with member firms regarding their use of GenAI. Below we highlight how FINRA is using GenAI to perform its self-regulatory functions more effectively…
SEC Grants No-Action Relief to Registered Investment Advisers and Certain Registered Investment Companies to Treat a State Trust Company Providing Crypto Asset Custody Services as a “Bank”
On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); and (ii) investment companies registered under the Investment Company Act of…