Steffen Hemmerich

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On February 28, 2025, House Financial Services Committee Chairman French Hill (R-AR), Senate Banking Committee Chairman Tim Scott (R-SC), and Senator Tom Cotton (R-AR) sent a letter (the “Letter”) to Securities and Exchange Commission (the “Commission”) Acting Chair Mark Uyeda requesting that the Commission launch a comprehensive review of all aspects of the Consolidated Audit…

On February 21, 2025, Commissioner Hester Peirce released a statement inviting input from interested parties on the regulation of crypto assets.  Commissioner Peirce stated that greater crypto clarity requires the public’s input, and the Crypto Task force therefore welcomes “input from anyone in the public with an interest in these topics, and a wide range…

The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2025 Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2024. This year, the Report adds new topics relating to the third-party risk landscape, registered index-linked annuities and extended hours trading. The Report also includes new content…

On February 19, 2025, the Securities and Exchange Commission (the “Commission” or “SEC”) dropped its appeal of a ruling by the U.S. District Court for the Northern District of Texas (“District Court”) on November 6, 2024 that struck down the Commission’s “Dealer Rule.”

The Dealer Rule, adopted by the SEC on February 6, 2024, further…

On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (FINRA), announced that FINRA will not set an effective date for its recent amendments (the “Amendments”) to Trade Reporting and Compliance Engine (TRACE) reporting rules to reduce the current 15-minute timeframe to one minute for reporting transactions…

On December 31, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-18 (“RN 24-18”) to provide updated guidance to members regarding Rules 15c3-1, 15c3-3 and 17a-5 under the Securities Exchange Act of 1934 (“SEA”), Rule 204 under Regulation SHO, FINRA Rules 4210, 4230(b), 4521 and 4524, and Regulation T of the Federal…

On December 16, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) requiring the electronic filing, submission, or posting of certain forms required under the Securities Exchange Act of 1934 and the rules and regulations thereunder, using structured, machine-readable data language as appropriate. The SEC also adopted amendments to the Financial and Operational…

Priorities Include Artificial Intelligence and Other Emerging Technologies, Complex Products, Reg BI, Cybersecurity, Outsourcing, Private Funds and Compliance with New and Amended SEC Rules

On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released its examination priorities for fiscal year 2025 (which started October 1, 2024).

The Cyber and Analytics Unit within the Member Supervision program of the Financial Industry Regulatory Authority, Inc. (“FINRA”) recently published a cybersecurity advisory regarding increasing cybersecurity risks at third-party providers (the “Cybersecurity Advisory”). The Cybersecurity Advisory highlights third-party risks to FINRA member firms and effective practices to mitigate such risks.  

FINRA’s advisory comes at a…

On August 14, 2024, FINRA published an update (the “Update”) on its ongoing efforts to engage with its members related to crypto asset activities. The Update describes “crypto assets” as assets that are issued or transferred using distributed ledger or blockchain technology. They include, but are not limited to, so-called virtual currencies, coins, and tokens.