This is a regulatory chocolate box, with something for every broker-dealer. In addition to perennial topics that generally appear on FINRA's Annual Priorities Letters, the new areas of focus include compliance with requirements under recent rulemakings, including Reg. BI and Form CRS, and technology-related topics, including cybersecurity, digital asset transactions and high-frequency trading. The contains "practical considerations and questions" that FINRA will consider in assessing firms…
This case is a reminder that failure to adopt required written procedures may be sufficient grounds for enforcement action even in the absence of any underlying rule violations. In this case, there was no allegation that the firm failed to execute orders in accordance with applicable regulatory requirements. Rather, the concern was that the absence of the required written methodology created a "substantial risk" that orders would not be executed in accordance with applicable regulatory…
This is a measured rule release that incorporates existing CFTC staff no-action relief into Part 4 of the CFTC Rules. Just as significant as what the CFTC included in the rule release is what the CFTC chose to omit:
Cross-Border Regulation: The CFTC decided to defer consideration of certain proposals affecting CPOs engaged in cross-border activities in light of concerns that the proposals "could have a significant impact on the compliance burdens of CPOs operating outside of the…
Proposed Amendments to Advertising Rule: The SEC proposal adopts a technology-neutral, principles-based approach to investment adviser advertising. Industry participants should carefully consider whether to submit responses.
One issue that is not specifically addressed in the Release is the degree to which the proposed rules should be harmonized more closely with equivalent FINRA standards for broker-dealer communications and NFA standards for promotional material distributed by CFTC-…
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This is a regulatory chocolate box, with something for every broker-dealer. In addition to perennial topics that generally appear on FINRA's Annual Priorities Letters, the new areas of focus include compliance with requirements under recent rulemakings, including Reg. BI and Form CRS, and technology-related topics, including cybersecurity, digital asset transactions and high-frequency trading. The contains "practical considerations and questions" that FINRA will consider in assessing firms…
This case is a reminder that failure to adopt required written procedures may be sufficient grounds for enforcement action even in the absence of any underlying rule violations. In this case, there was no allegation that the firm failed to execute orders in accordance with applicable regulatory requirements. Rather, the concern was that the absence of the required written methodology created a "substantial risk" that orders would not be executed in accordance with applicable regulatory…
This is a measured rule release that incorporates existing CFTC staff no-action relief into Part 4 of the CFTC Rules. Just as significant as what the CFTC included in the rule release is what the CFTC chose to omit:
Cross-Border Regulation: The CFTC decided to defer consideration of certain proposals affecting CPOs engaged in cross-border activities in light of concerns that the proposals "could have a significant impact on the compliance burdens of CPOs operating outside of the…
Proposed Amendments to Advertising Rule: The SEC proposal adopts a technology-neutral, principles-based approach to investment adviser advertising. Industry participants should carefully consider whether to submit responses.
One issue that is not specifically addressed in the Release is the degree to which the proposed rules should be harmonized more closely with equivalent FINRA standards for broker-dealer communications and NFA standards for promotional material distributed by CFTC-…