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SEC Release The SEC voted to propose Rule 15Fi-1 under the Exchange Act to require security-based swap dealers and major security-based swap participants to provide counterparties with a trade acknowledgment detailing information specific to the transaction. Among other things, the new rule specifies (1) when a counterparty must be provided with a trade acknowledgment; (2) written policies and procedures that must be in place and designed to obtain verification of the terms outlined in the trade acknowledgment; (3) which entity is responsible for providing a trade acknowledgment; (4) the

SEC Release No. 34-64884 ; SR-FINRA-2011-033 July 14, 2011 The SEC declared immediately effective a FINRA proposal to adopt new FINRA Rule 0180, regarding the application of FINRA's rules to security-based swaps. The new rule seeks to provide relief akin to what the SEC has already provided, e.g., the rule does not grant relief from certain FINRA conduct rules. In particular, the new rule does not exempt security-based swaps from (i) FINRA Rule 2010 (standards of commercial honor and principles of trade); (ii) FINRA Rule 2020 (antifraud rule); (iii) FINRA Rule 3310 (AML program); and (iv)

FINRA published this comment request on a revised proposal addressing debt research conflicts of interest, which includes some fairly substantial amendments to FINRA's previously proposed rule as to research on debt securities as originally set forth in FINRA Reg. Notice 11-11 . Among the changes made by new rule proposal to original rule proposals are: an exemption from the rule would be provided for research distributed to a very limited tier of institutional investors; an exemption would be provided as to firms that engaged in limited principal debt trading activity; the definition of "debt

In accordance with Dodd-Frank, the SEC is proposing capital and margin requirements for security-based swap dealers ("SBSDs") and major security-based swap participants ("MSBSPs"), segregation requirements for SBSDs, and notification requirements with respect to segregation for SBSDs and MSBSPs. The SEC also is proposing to increase the minimum net capital requirements for broker-dealers permitted to use the alternative internal model-based method for computing net capital. The SEC's proposed rules are intended to accomplish the following: Set minimum capital requirements for security-based

Technical corrections are being made to SEC Release 77 FR 70213 , which proposed capital and margin requirements for security-based swap dealers ("SBSDs") and major security-based swap participants ("MSBSPs"). The release also proposed segregation requirements for SBSDs and notification requirements with respect to segregation for SBSDs and MSBSPs, as well as increases to the minimum net capital requirements for broker-dealers permitted to use the alternative internal model-based method for computing net capital. Cross-Reference(s) : Dodd-Frank Section 763 (Amendments to the Securities