Steffen Hemmerich

Subscribe to Steffen Hemmerich's Posts

In a post by its Head of Examinations, Jim Reese, the Financial Industry Regulatory Authority, Inc. (“FINRA”) announced a series of meaningful changes to its examination program as part of its “FINRA Forward” initiative.  The changes are designed to make the exam process more transparent and efficient, and more closely tied to risk assessments.  These…

On July 24, 2026, the Securities and Exchange Commission (the “SEC”) approved the Financial Industry Regulatory Authority, Inc.’s (“FINRA”) proposed amendments to FINRA Rules 5110 and 5123, which were filed with the SEC in January 2026 as part of FINRA’s Forward initiative to modernize the capital formation process.

As discussed in our prior post from…

On July 16, 2026, the U.S. Securities and Exchange Commission (the “SEC”) proposed new Regulation E-Delivery (“Reg E-Delivery”), a potential modernization of the default manner in which issuers, broker-dealers, investment advisers, and other market participants provide information to investors in our increasingly electronic world. In the words of SEC Chairman Paul Atkins, “[t]oday, the Commission…

On July 9, 2026, the Financial Industry Regulatory Authority, Inc. (“FINRA”) published Regulatory Notice 26-14, requesting comment on a proposal to modernize certain requirements applicable to retail communications under FINRA Rule 2210 (Communications with the Public) (the “Proposal”).  The Proposal represents one of the most significant modernization efforts relating to the review and supervision…

On June 10, 2026, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) published a notice of proposed rulemaking (the “Proposal”) suggesting comprehensive amendments to CFTC Regulation 40.11 and adding a new Appendix F to Part 40 concerning event contracts traded on prediction markets. The Proposal would further specify the types of event contracts…

FINRA is conducting a targeted review of member firm practices related to the supervision of non-principal protected “worst-of” structured notes over a look-back period of 2022 through the end of 2025.  FINRA’s focus is on Regulation Best Interest, including the Care Obligation, and how member firms supervise customer concentrations in “worst-of” structured notes.  FINRA is…

In April 2026, FINRA published its report titled “FINRA Forward: A Year of Progress,” which provides a recap of the regulatory changes implemented by FINRA as part of its rule modernization initiative.  The report also provides insight into pending rule proposals and other policy initiatives.

Rule Changes and Guidance

FINRA highlights significant rule changes, including…

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…