Steffen Hemmerich

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The Securities and Exchange Commission (“SEC”) issued an order approving proposed amendments (the “Proposed Amendments”) by The Nasdaq Stock Market LLC (“Nasdaq” or “Exchange”) to the Exchange’s rules to enable trading of certain securities in tokenized form during the pendency of a tokenization pilot program (the “DTC Pilot”) operated by The Depository Trust Company (“DTC”).…

FINRA’s proposal would expand investor access to performance projections and targeted returns to more closely align FINRA Rule 2210 with the IA Marketing Rule

The Financial Industry Regulatory Authority, Inc. (“FINRA”) recently filed with the U.S. Securities and Exchange Commission proposed amendments (the “Proposed Amendments”) to FINRA Rule 2210 (Communications with the Public) to permit…

On March 12, 2026, the Commodity Futures Trading Commission (“CFTC”) released two documents regarding “event contract” derivatives traded on prediction markets. The CFTC issued an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the regulation of prediction markets. The CFTC’s Division of Market Oversight issued a staff advisory providing guidance to designated contract…

Brazil has emerged as one of the world’s most dynamic and tightly regulated wealth markets. Local investors are increasingly sophisticated, and appetite for offshore products has never been higher. For U.S. broker-dealers and investment advisers, the opportunity is clear: Brazilian clients want access to global markets and U.S. platforms are well positioned to provide it.…

Amendments increase the annual gift limit to $300, provide exemptive relief authority, codify existing guidance and clarify that the rule does not apply to gifts to individual retail customers

On February 12, 2026, the U.S. Securities and Exchange Commission approved the Financial Industry Regulatory Authority, Inc.’s (“FINRA”) amendments (the “Amendments”) to FINRA Rule 3220 (Influencing…

On February 19, the staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission issued an FAQ, stating the staff will not object if a broker-dealer treats a proprietary position in a payment stablecoin (as defined in the FAQ) as having a “ready market” under SEC Rule 15c3-1 and takes…

The Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 26-03 (the “Notice”) consolidating guidance on the use of negative consent letters for bulk transfers or assignments of customer accounts between FINRA members. Moreover, the Notice eliminates the current practice of submitting draft negative consent letters to FINRA staff for review; this change will become…

On December 11, 2025, the staff of the Division of Trading and Markets of the Securities and Exchange Commission issued a no-action letter to The Depository Trust Company (“DTC”) concerning a pilot version (the “Preliminary Base Version”) of a securities tokenization program, referred to as the “DTCC Tokenization Services.” The letter permits DTC to conduct…

On December 17, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the Securities and Exchange Commission (“SEC”) released an update to its May 2025 FAQs relating to crypto asset activities and distributed ledger technology.  The additional FAQs focus on trading and settlement issues, including how alternative trading systems (“ATSs”) and…

On December 17, 2025, the Staff of the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) issued a statement explaining its views on the application of paragraph (b)(1) of SEC Rule 15c3-3 to broker-dealers seeking to establish custody of crypto asset securities.  The statement focuses on broker-dealers’ “physical…