FINRA issued a regulatory notice regarding the 2015 Renewal Program, which begins on November 10, 2014. FINRA will make the Preliminary Renewal Statements available to all firms on the Web CRD/IARD. FINRA added that firms should note the following key dates in the renewal process: October 27, 2014: Firms may begin submitting postdated Form U5 and BR Closing/Withdrawal filings via Web CRD/IARD. November 1, 2014: Firms may begin submitting postdated Form BDW and ADV-W filings via Web CRD/IARD. Please Note: Postdated filings submitted by 11 p.m., Eastern Time (ET), on November 7, 2014 do not
News & Insights
The FINRA-proposed revision to the implementation date for the Supplemental Inventory Schedule ("SIS") was filed to be effective immediately and published in the Federal Register. The due date for the first SIS, for the disclosure of inventory positions during the reporting period ending on December 31, 2014, will be January 30, 2015. While the proposal is effective immediately, comments may be submitted until November 17, 2014. See: 79 FR 63996. Related news: SEC Approves FINRA Supplemental Inventory Schedule (FINRA Reg. Notice 14-43) (October 23, 2014); FINRA Proposes to Revise the
FinCen issued two administrative rulings regarding proposed business models of two companies engaged in services relating to virtual currency. One company sought a ruling regarding its virtual currency payment system and the other sought guidance about a proposed virtual currency trading platform. In the two rulings, FinCEN held that the proposed business activities of the companies seeking guidance required those companies to comply with all FinCEN regulations applicable to money transmitting businesses, even though both companies claimed that their particular platforms and systems did not
The CFTC announced that it will hold an open meeting on November 3, 2014. At the open meeting, the CFTC will consider: CFTC rules concerning when "residual interest" must be posted by futures commission merchants; recordkeeping requirements under CFTC Rule 1.35 ("Records of Commodity Interest and Related Cash or Forward Transactions"), and whether to conform the text of the rule to no-action relief already granted by CFTC staff; and clarifications of the CFTC's interpretation of when an agreement, contract or transaction that contains embedded volumetric optionality falls within the forward
The U.S. District Court for the Middle District of North Carolina (the "Court") issued an order imposing permanent trading and registration bans on an individual for registration violations and the failure to include certain required disclosures on his website. According to the order, the individual used various methods of interstate commerce, including mail, to offer his services as a CTA in exchange for payment in the form of either flat charges or a percentage of profits from customers. Additionally, the individual used his website to solicit clients to subscribe to his "e-mini S&P 500