March 28, 2017
Client Alert: SEC Adopts T+2 Settlement Cycle for Securities Transactions
On March 22, 2017, the Securities and Exchange Commission (“SEC”) adopted an amendment to Rule 15c6-1(a) under the Securities Exchange Act of 1934 (“Exchange Act”), shortening the standard settlement cycle (i.e., the length of time between trade execution and delivery of cash and securities to the seller and buyer) for…
September 30, 2016
SEC Proposes to Shorten Securities Settlement Cycle
During an Open Meeting on September 28, 2016, the U.S. Securities and Exchange Commission (“SEC”) proposed a rule amendment to expedite the process for settling securities transactions.
May 27, 2016
FINRA Proposes Immediately Effective Clarifications to the Debt Research Rule
FINRA proposed amendments (SR-FINRA-2016-017) to the debt research rule (FINRA Rule 2242 – Debt Research Analysts and Debt Research Reports), which addresses conflicts of interest relating to the publication and distribution of debt research reports. The proposed amendments clarify the application of the rule in four respects: (1) The consent requirement for institutional debt research reports distributed to non-U.S. investors by non-U.S. affiliates of broker-dealers; (2) The consent requirement for institutional debt research reports distributed to specified persons for informational purposes unrelated to investing in debt securities; (3) The scope of the institutional debt research report exemption when distributing third-party debt research reports to eligible institutional investors; and (4) The disclosure requirements for debt research analysts in public appearances.
July 27, 2015
FINRA Comments on DOL Proposed Conflict of Interest Rule and Related Proposals
On July 17, 2015, FINRA submitted comments on the DOL’s April 14, 2015 proposals, which included amendments to the definition of “fiduciary,” a proposed best interest contract exemption, and a proposed exemption for principal transactions in certain debt securities. FINRA’s comments support the implementation of a best interest standard for…
July 20, 2015
FINRA Requests Comment on a Revised Proposal to Adopt a Consolidated FINRA Rule Regarding Discretionary Accounts and Transactions
On June 17, 2015, FINRA issued a request for comment on a revised proposal to adopt a new FINRA Rule 3260 for Discretionary Accounts and Transactions by Persons other Than the Customer. The accompanying Regulatory Notice 15-22 proposes to revise and consolidate NASD Rule 2510 and Incorporated NYSE Rule 408…
July 6, 2015
FINRA Proposes Changes to Rules Governing Communications with the Public
On April 16, 2015 FINRA announced proposed amendments and revisions to FINRA rules governing communications with the public. The proposed changes are part of a retrospective rule review launched by FINRA in April 2014 and are aimed at better aligning the investor protection benefits and economic impacts of these rules. The proposed amendments revise the filing requirements in FINRA Rules 2210 and 2214 and the content and disclosure requirements in FINRA Rule 2213.
June 12, 2015
FINRA Seeks Comment on Concept Proposal to Restructure Qualification Examination Program
On May 27, 2015, FINRA issued a request for comment on a concept proposal to restructure the current representative-level qualification examination program. In an effort to reduce the content overlap across the representative-level examinations and requirements for individuals in various segments of the industry, the new format would consist of a general knowledge examination (the Securities Industry Essentials Examination, or “SIE”) and an appropriate specialized examination to reflect each particular registered role.
June 5, 2015
FINRA Amendments to Rule 8311 to become effective August 24, 2015
The amendments to FINRA Rule 8311 clarify the scope of the rule on payments by member firms to persons subject to sanctions and eliminate duplicative provisions in NASD IM–2420–2.
June 5, 2015
FINRA Rule on Payments to Unregistered Persons to become effective August 24, 2015
FINRA Rule 2040 consolidates NYSE and NASD rules and NASD guidance on the payment of fees to unregistered persons. The new rule will become effective on August 24, 2015.
July 30, 2014
Revisions to FINRA Rule 5210 to Address Self-Trades
On August 25, 2014, firms must enact policies and procedures to address self-trading from algorithms and trading desks, in accordance with new supplementary material to FINRA Rule 5210. In particular, the firm must reasonably design policies and procedures that pertain to a single algorithm or trade desk (or related algorithms…