February 27, 2013

SEC No-Action Relief for Broker-Dealers Relying on Registered Investment Advisers for Anti-Money Laundering Obligations

The SEC has extended a former no-action letter position that permitted broker-dealers to rely on SEC registered investment advisers to perform its customer identification obligations for shared customers.  The former position allows broker-dealers to rely on certain financial institutions to meet customer identification obligations under Rule 17a-8 of the Securities Exchange Act of 1934 as long as the institution is subject to an anti-money laundering program regulated by a federal regulator.

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February 27, 2013

FINRA 2013 Examination Priorities

On January 11, 2013, FINRA released its 2013 examination priorities letter.  The letter identifies four primary categories as the focus of FINRA’s upcoming examinations and enforcement efforts – Business Conduct and Sales Practice Priorities, Insider Trading, Financial and Operational Priorities, and Market Regulation Priorities.  Within…

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February 22, 2013

SEC 2013 Examination Priorities

On February 21, 2013 the SEC released its 2013 examination priorities. The SEC states that with respect to broker-dealers it is going to continue to focus on sales practice/fraud, trading, capital, and AML. New issues of concern for the examination process are: the market access rule,…

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