FINRA issued a regulatory notice regarding recent revisions to the Series 23 and 24 examination programs. Specifically, the revisions update the material to reflect changes in the laws, rules and regulations covered by the examinations and to incorporate the functions and associated tasks currently performed by a General Securities Principal. The changed content outlines will appear in the Series 23 and 34 examinations administered on or after October 13, 2014. See : FINRA Regulatory Notice 14-33. Related news: FINRA Proposes Rule Amendments to Revise Series 23 and 24 Examination Programs (Fed
News & Insights
On August 13, 2014, the Office of Foreign Assets Control ("OFAC") issued revised guidance applicable to its economic sanctions programs, including those related to Ukraine. In particular, OFAC clarified the application of rules related to the blocking of property in which more than one blocked person has an interest. According to OFAC's previously issued guidance, the property of a blocked person is itself blocked by operation of law if the blocked person owns, directly or indirectly, a 50% or greater interest in the property. Thus, for example, a company in which an individual or entity named
The MSRB issued a request for comments from municipal market stakeholders on a proposal to enhance the public availability of municipal securities trade data on the MSRB's Electronic Municipal Market Access ("EMMA") Web site. Among the proposed new data elements are the following: (i) information about trades in new issues that result from conditional allocations by dealers, (ii) information regarding sale transactions by dealers that have long-term marketing agreements with underwriters, and (iii) information about transactions executed through alternative trading systems. Additionally, the
In his speech at the New York Conference on the Risks of Wholesale Funding, President of the Federal Reserve Bank of Boston Eric S. Rosengren stated that there should be a "comprehensive re-evaluation" of the capital regulation of broker-dealers ( i.e., intermediaries that effect transactions in securities), given the lessons of the financial crisis. In other words, the capital regulations imposed on broker-dealers should be raised materially. According to Mr. Rosengren, the market's perception that broker-dealers were not financially sound because they did not hold enough capital resulted in
The SEC proposed an amendment to Investment Advisers Act Rule 206(3)-3T to extend the date as to when the rule would sunset. The proposed extension is from December 31, 2014 to December 31, 2016. Rule 206(3)-3T is a 2007 temporary rule establishing an alternative means for investment advisers registered with the SEC as broker-dealers to meet the requirements of Investment Advisers Act Section 206(3) ("Prohibited Transactions by Investment Advisers"). The rule applies when these advisers act in a principal capacity in transactions with certain advisory clients. The comment deadline will occur