All posts by Daniel LeGaye

Implementation Deadline for Amended Electronic Recordkeeping Rules for Broker-Dealers Nears

In October 2022, the Securities and Exchange Commission (“SEC”) adopted amendments to the recordkeeping rules applicable to broker-dealers, security-based swap dealers, and major security-based swap participants. The amendments impacting broker-dealers … Continue reading Implementation Deadline for Amended Electronic Recordkeeping Rules for Broker-Dealers Nears

Revisions to Cash Solicitation Rule Proposed for Investment Advisers (Part 3 of 3)

As noted previously, the Securities and Exchange Commission (“SEC”) announced that it is releasing proposed amendments to the advertising and cash solicitation rules that currently provide for the regulatory framework … Continue reading Revisions to Cash Solicitation Rule Proposed for Investment Advisers (Part 3 of 3)

Updated Cash Solicitation and Advertising Rules Proposed for Investment Advisers (Part 2 of 3)

As noted previously, the Securities and Exchange Commission (“SEC”) has announced that it is releasing proposed amendments to the cash solicitation and advertising rules that impact investment advisers.  In this … Continue reading Updated Cash Solicitation and Advertising Rules Proposed for Investment Advisers (Part 2 of 3)

Updated Advertising and Cash Solicitation Rules Proposed for Investment Advisers (Part 1 of 3)

The Securities and Exchange Commission (“SEC”) has announced that it is releasing proposed amendments to the advertising and cash solicitation rules impacting investment advisers.  The proposed amendments are to the … Continue reading Updated Advertising and Cash Solicitation Rules Proposed for Investment Advisers (Part 1 of 3)

FINRA Points to Fair and Balanced Customer Communications Regarding Departing Registered Representatives

The Financial Industry Regulatory Authority (FINRA) has consistently sought to ensure that customers can make a timely and informed choice about where to maintain their assets when their registered representative … Continue reading FINRA Points to Fair and Balanced Customer Communications Regarding Departing Registered Representatives

Cantor Fitzgerald Fined $2 Million by FINRA for Regulation SHO Violations and Supervisory Failures

The Financial Industry and Regulatory Authority (FINRA)  announced that it has fined Cantor Fitzgerald & Co. (Cantor) $2 million for Regulation SHO (Reg SHO) violations and supervisory failures spanning a … Continue reading Cantor Fitzgerald Fined $2 Million by FINRA for Regulation SHO Violations and Supervisory Failures

CAB Rule Amendments Proposed by FINRA to Address Qualification Requirements

The Financial Industry and Regulatory Authority (“FINRA”) has filed a proposed rule change with the Securities and Exchange Commission (“SEC”) and is soliciting comments to amend the Capital Acquisition Broker … Continue reading CAB Rule Amendments Proposed by FINRA to Address Qualification Requirements

Compliance Deficiencies Targeted in FINRA’s 2018 Examination Findings Report

The Financial Industry Regulatory Authority (“FINRA”) recently issued its 2018 Examination Findings Report that reflects a summary of its examination findings for broker-dealers (“firms” or “members”) in 2018.   For members, … Continue reading Compliance Deficiencies Targeted in FINRA’s 2018 Examination Findings Report

SEC Provides Investment Advisers Guidance Relating to Electronic Messaging

The Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”) conducted a limited-scope examination initiative of registered investment advisers (“advisers”) that was designed to provide … Continue reading SEC Provides Investment Advisers Guidance Relating to Electronic Messaging

FINRA Proposes Amendment to Rule 1220 for Firms Exempt from FINOP Requirement

Financial Industry Regulatory Authority, Inc. (“FINRA”) filed  a proposed rule change with the Securities and Exchange Commission to amend FINRA Rule  Rule 1220(a)(4) (Financial and Operations Principal and Introducing Broker-Dealer … Continue reading FINRA Proposes Amendment to Rule 1220 for Firms Exempt from FINOP Requirement

FINRA Proposes New Rule on Outside Business Activities and Private Securities Transactions

FINRA seeks comments on a proposed new rule to consolidate FINRA Rule 3270 (Outside Business Activities of Registered Persons) and FINRA Rule 3280 (Private Securities Transactions of an Associated Person).  … Continue reading FINRA Proposes New Rule on Outside Business Activities and Private Securities Transactions

SEC’s Observations on the Elements of Robust Cybersecurity Policies and Procedures

The Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections (“OCIE”) issued a Risk Alert that provides its observations on the elements of robust cybersecurity policies and procedures.  Those observations … Continue reading SEC’s Observations on the Elements of Robust Cybersecurity Policies and Procedures

SECs Cybersecurity Examination Initiative Notes Firms Should Improve Cybersecurity

The Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections (“OCIE”) has issued a Risk Alert that provides observations on cybersecurity arising from OCIE’s examinations conducted pursuant to the Cybersecurity … Continue reading SECs Cybersecurity Examination Initiative Notes Firms Should Improve Cybersecurity

Rules on Outside Business Activities and Personal Securities Transactions Under Review

The Financial Industry Regulatory Authority (“FINRA”) has announced, both in Regulatory Notice 17-20, and in a session regarding the topic at the recent 2017 FINRA Annual Conference in Washington DC, … Continue reading Rules on Outside Business Activities and Personal Securities Transactions Under Review