Videos

From Two Rules to One: FINRA’s Rule 3290 Will Reshape Supervision of OBAs and PSTs

Introduction In 2025, the Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 25-05, proposing new Rule 3290 to modernize and consolidate its long-standing requirements for outside business activities (“OBAs”) and … Continue reading From Two Rules to One: FINRA’s Rule 3290 Will Reshape Supervision of OBAs and PSTs

Regulation S-P, NPI, and Sub-Advisers: When “Sub-Advisers” Are Vendors – and When They Are Not

Executive Summary The Securities and Exchange Commission’s (SEC) 2024 amendments to Regulation S-P significantly reshaped advisers’ privacy and cybersecurity obligations, particularly in service-provider oversight and the timing of breach notifications … Continue reading Regulation S-P, NPI, and Sub-Advisers: When “Sub-Advisers” Are Vendors – and When They Are Not

Off-Channel Communications Start in Email: Are Your Keywords Keeping Up?

Executive Summary Regulators continue to focus on “off-channel” communications—business-related messages conducted outside a firm’s approved system. While much of the enforcement attention has centered on text messaging and collaboration apps, … Continue reading Off-Channel Communications Start in Email: Are Your Keywords Keeping Up?

Why High-Net-Worth Clients Can Turn an Institutional Communication into a Retail Communication Violation

Overview Small and mid-size broker-dealers increasingly rely on the institutional communication exemption under FINRA Rule 2210 to distribute marketing decks and performance-based marketing materials to clients and prospects. The exemption … Continue reading Why High-Net-Worth Clients Can Turn an Institutional Communication into a Retail Communication Violation