FINRA's guidance follows a number of relating to the handling of UTMA and UGMA accounts.

Given the size of the Bitcoin market and the fact that futures trading of Bitcoin has been going on for a while without problems, it would seem likely at this point that the SEC's refusal to permit the listing of Bitcoin ETFs is founded and its desire not to encourage further retail investment, including indirect investment, in the product. Although one can be sympathetic to the SEC's worries as to retail investors, the SEC is not supposed to serve as a gatekeeper on the wisdom of…

The FDIC Guide serves a number of related purposes: (i) it provides assistance to technology firms by instructing them on how to market to banks and to respond to request for quotes (RFQs); (ii) it summarizes for banks the minimum materials that they should be requesting from technology firms from which they obtain services; and (iii) it makes it easier for banks to negotiate with technology firms by laying out the diligence and contractual requirements that banks should obtain from…

This is actually quite a significant targeted exam letter. It has relevance well beyond those firms that have a zero commission offering. FINRA is asking very detailed questions about how the firm makes money, and how the firm's revenue stream affects the manner in which the firm does business and treats customers.

The type of information that the letter is intended to elicit includes information that would be relevant to the completion of Form CRS that is to be provided to clients.…