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In a filing with the SEC, FINRA proposed to amend NASD Rule 1022 ("Categories of Principal Registration") and NASD Rule 1032 ("Categories of Representative Registration") to remove the deadline by which eligible registrants must complete a firm-element continuing education requirement to engage in a security futures business, and to remove reference to a revised examination.

Steven Lofchie Commentary by Steven Lofchie

The Office of the Comptroller of the Currency ("OCC"), the Board of Governors of the Federal Reserve ("FRB") and the Federal Deposit Insurance Corporation ("FDIC") held the sixth and final Economic Growth and Regulatory Paperwork Reduction Act ("EGRPRA") Outreach Meeting. FRB Governor Daniel K. Tarullo stated that comments received from the EGRPRA's required joint review of the FRB by federal banking agencies focused on: (i) simplifying the regulatory capital rules for smaller community banks; (ii) modifying the types and amounts of information collected by the quarterly Consolidated Report of

The NFA issued guidance on the annual affirmation requirement for entities currently operating under an exemption or exclusion from Commodity Pool Operator or Commodity Trading Advisor registration. The NFA specified that, following December 2, 2016, any person or entity claiming an exemption or exclusion under CFTC Rules 4.5 (Exclusion for Certain Otherwise Regulated Persons from the Definition of the Term 'Commodity Pool Operator'), 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5) (Exemption from Registration as a Commodity Pool Operator) or 4.14(a)(8) (Exemption from Registration as a

SIFMA recommended changes to Regulation S-X to improve the quality of disclosure for investors while making the registration process less burdensome for the [SEC] and registrants. SIFMA made the following recommendations: S-X Rule 1-02(w): (i) replace the income test with a test based on the revenues of each entity; (ii) eliminate the asset test; and (iii) replace the investment test with a test based on the purchase price as a percentage of the market capitalization of the registrant for certain public company registrants; S-X Rule 3-05: adjust the significance thresholds that determine the

Steven Lofchie Commentary by Steven Lofchie

SIFMA recommended changes to FINRA's proposed rules contained in Regulatory Notice 15-37 addressing the financial exploitation of seniors and other vulnerable adults. In a comment letter, SIFMA offered the following changes to Proposed Rule 2165 ("Financial Exploitation of Specified Adults"): The Reporting Process: It is important to include government agencies and other financial institutions as part of the permissible reporting structure to ensure the highest possible level of investor protections. Reporting to a trusted contact or an immediate family member should be voluntary and separate