On January 10, 2023, the Financial Industry Regulatory Authority, Inc. (“FINRA”) published the 2023 Report on its Examination and Risk Monitoring Program (the “Report”). FINRA highlights several topics as key areas of risk for investors and the markets, including mobile apps, complex products and options, order handling/best execution, Regulation Best Interest and Form CRS, and
FINRA Releases 2023 Report on Its Examination and Risk Monitoring Program
On January 10, 2023, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report), available at: 2023 Report on FINRA’s Examination and Risk Monitoring Program. The Report details findings from FINRA’s recent oversight activities of the FINRA Member Supervision, Market Regulation and Enforcement programs.
SEC Staff Grants Temporary Relief from Compliance with Rule 15c2-11 for Rule 144A Fixed Income Securities
With the January 3, 2023, deadline fast approaching for compliance with Exchange Act Rule 15c2-11, as amended and reinterpreted by the staff of the US Securities and Exchange Commission (“SEC”) to apply to fixed income securities (the “Rule”), the SEC staff granted some temporary relief in a new no-action letter on November 30. Participants in
SEC Staff Provides Extension of Relief on Rule 15c2-11
The SEC’s Division of Trading and Markets has issued a no action letter that extends its prior relief as currently provided under “Phase 1” in its prior letter in relation to the application of Rule 15c2-11 to fixed income securities, now providing an extension until January 2025.
See the relief here. A client alert
Rule 15c2-11: SEC “Clarification” of Broker-Dealer Focused Rule Sending Shockwaves Through Debt Capital Markets
August 17, 2022 Webinar
1:00pm – 2:00pm ET
Register here.
This PLI briefing will provide an overview of a December 2021 SEC clarification that it would begin applying Rule 15c2-11 to broker-dealer quotations for fixed income securities, including securities traded under Rule 144A among QIBs. This “clarification” would require private “Rule 144A” issuers to
SEC Rule Proposal Seeks to Clarify “Dealer” Definition for Persons Engaging in Liquidity-Providing Activities
Proposed Rules Could Require Dealer Registration by Certain Principal Trading Firms, Private Funds, Investment Advisers and Other Market Participants
On March 28, 2022, the US Securities and Exchange Commission (“SEC”) proposed two new rules – SEC Rules 3a5-4 and 3a44-2 (the “Proposed Rules”) – that would further define the phrase “as part of a regular
US Securities and Exchange Commission Division of Examinations 2022 Exam Priorities
On March 30, 2022, the Division of Examinations of the US Securities and Exchange Commission (“SEC”) announced its examination priorities for 2022. This year’s priorities specifically focus on: (i) private funds; (ii) environmental, social and governance investing; (iii) standards of conduct, including Regulation Best Interest, fiduciary duty and Form CRS; (iv) information security and operational
SEC Proposes to Remove Credit Ratings References from Regulation M
On March 23, 2022, the US Securities and Exchange Commission (the “SEC”) proposed amendments to remove references to credit ratings from Regulation M, replace them with alternative measures of creditworthiness and impose related recordkeeping obligations on broker-dealers (the “Proposal”). Our Legal Update discusses key elements of the SEC’s Proposal.
Read the complete Legal Update.
FINRA Publishes 2022 Report on Its Examination and Risk Monitoring Program
FINRA adds new topics for 2022 and new material to previously covered topics.
On February 9, 2022, the Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2022 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”). FINRA intends for the Report to be an up-to-date, evolving resource for firms that may help inform their
The Social Media Guide: Social Media Compliance for Issuers, Broker-Dealers, & Investment Advisers
You are an issuer, investment adviser, or broker-dealer. You want to communicate to the public about securities. Should you (a) type a letter and drop it in the mailbox; (b) chisel out a prospectus on two stone tablets; or (c) use social media?
If you chose (c),