FINRA issued a regulatory notice requesting comments on a proposed rule that would require an educational communication be provided to customers of a transferring representative. The education communication highlights key considerations in transferring assets to the recruiting firm including the direct and indirect impacts of such a transfer on those assets. The proposed rule would require a member firm that hired or associated with a registered representative to provide such an education communication to former retail customers whom the member firm, directly or through the transferring

FINRA issued a regulatory notice regarding the SEC's recent approval of amendments to the definitions of "non-public arbitrator" and "public arbitrator" in the FINRA Customer and Industry Codes of Arbitration Procedure. According to FINRA, the amended definitions provide that persons who worked in the financial industry for any duration during their careers will be classified always as non-public arbitrators, but that persons who represent investors or the financial industry as a significant part of their business will be classified as non-public and may become public arbitrators after a

The Board of Governors of the Federal Reserve System (the "FRB") published a "Feds Note" by FRB economists Neil Bhutta and Daniel Ringo. The article assesses the role of the Community Reinvestment Act (the "CRA") in precipitating the growth in subprime lending that led to the financial crisis. While conceding that the CRA provided an incentive structure that could motivate banks to originate or purchase riskier loans, the economists concluded that the CRA did not contribute significantly to the crisis. The economists noted that during the merger boom in the late 1990s, banks began promising

In MetLife, Inc. v. FSOC, MetLife Inc. v. FSOC, 15-cv-00045, U.S. District Court, District of Columbia, "fifteen law and finance professors from leading universities whose research focuses on financial regulation and administrative law, including [Dodd-Frank]," submitted an Amici curiae brief on behalf of the FSOC containing "analysis and academic research" in support of FSOC's determination that MetLife should be regulated as systemically significant. The professor's argue that a court has the authority to overturn the determination of FSOC only if such determination was "arbitrary and

The North American Securities Administrators Association ("NASAA") named Joseph Brady its new Executive Director. In his new role as Executive Director, Mr. Brady will work closely with NASAA's leadership and members, as well as industry and investor groups, other regulators and Capitol Hill lawmakers. He also will oversee NASAA's day-to-day operations. See: NASAA Press Release.