Despite the disruptive effect of COVID-19, the SEC does not intend to extend the effective dates for compliance with Reg. BI and Form CRS. In addition, the SEC’s Office of Compliance Inspections and Examinations recently announced its intention to begin examinations of registrants’ implementation of these new regulations. Such examinations are expected to occur during
FINRA Enforcement
FINRA’s 2019 Risk Monitoring and Examination Priorities Letter Highlights Broker-Dealer Online Distribution Platform Activities
FINRA recently published its 2019 Risk Monitoring and Examination Priorities Letter (“Priorities Letter”) highlighting topics upon which FINRA will focus in the coming year. Unlike letters in prior years, the Priorities Letter focuses primarily on areas that FINRA considers to be material new priorities. Of particular interest to the growing number of companies providing financial…
FINRA Asks Members: What Are You Doing with Digital Assets?
In a July 2018 regulatory notice (Regulatory Notice 18-20, available here: http://www.finra.org/sites/default/files/notice_doc_file_ref/Regulatory-Notice-18-20.pdf), FINRA has requested that members notify it if they engage, or intend to engage, in any activities related to digital assets, such as cryptocurrencies. In addition, until July 31, 2019, FINRA requests that firms notify their point of contact with FINRA, their…
FINRA updates its Frequently Asked Questions on new mark-up and mark-down disclosure rules for transactions in fixed income securities
On March 19, 2018, FINRA updated its guidance on its recent amendments to Rule 2232. The new requirements, which are currently scheduled to take effect on May 14, 2018, apply to transactions with retail customers (not institutional accounts, as defined in Rule 4512(c)[1]) in corporate and agency debt securities. Beginning on the effective…
FINRA Publishes FAQs on New Measures to Prevent the Financial Exploitation of Seniors
In January 2018, FINRA issued guidance on the provisions of Rule 2165 and the amendments to Rule 4512, which were approved in February 2017. The new requirements are aimed at preventing the financial exploitation of seniors, and are scheduled to take effect on February 5, 2018. The new FAQs principally reiterate prior guidance clarifying the…
FINRA Issues Report on Its Examination Findings
In December 2017, FINRA issued a report highlighting several key findings from its recent examinations of broker-dealer members. The report is available here.
The report focuses on several observations from recent examinations that FINRA believed would be worth highlighting to members. Of course, the report cannot list all of FINRA’s concerns; however, FINRA selected…
NASAA Survey Finds Seniors Are Most Vulnerable to Financial Fraud
On August 21, 2017, the North American Securities Administrators Association (“NASAA”) released a survey on senior citizens and financial exploitation. The survey of the state securities regulators highlighted, among other things, the need for the securities regulators to take a stronger role in prevention and detection.
The survey was conducted internally among NASAA’s membership of…