On Jan. 22, 2019, the Financial Industry Regulatory Authority (FINRA) released its 14th Annual Risk Monitoring and Examination Priorities Letter, where it identifies its areas of examination focus for 2019. The FINRA president’s cover note points out the addition to the title of a reference to “risk monitoring.” While the Priority Letter describes the
FINRA Plans Major Changes to Expungement Rules
FINRA recently issued Notice to Members 17-42, which proposes sweeping changes to the process by which a securities broker may seek to expunge reference to a customer complaint from his or her public record. The comment period for the proposed rule amendments ended on Feb. 5, 2018. The proposed changes will now to go…
FINRA Releases 2018 Annual Regulatory and Examinations Priorities
As it does every January, FINRA released its annual Regulatory and Examinations Priorities Letter identifying areas of examination focus for the coming year, recurring challenges faced by firms, and possible risks impacting the financial sector. FINRA’s 2018 exam priorities for the first time identify cryptocurrencies and related initial coin offerings (ICOs). Other first-mentions include technology…
Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues Conference
Shareholders Carl A. Fornaris and William B. Mack of global law firm Greenberg Traurig, LLP will be participating at the Financial Markets Association’s 2017 Treasury and Capital Markets Legal and Legislative Issues Conference, Oct. 25 – Oct. 26. Mack is also a member of the conference’s 2017 Program Planning Committee.
Fornaris will be moderating, “Recent…
SEC and FINRA Continue to Root Out Bad Brokers
On Thursday, July 27, regulators and industry professionals gathered in Washington, D.C. to discuss the current regulatory environment, cybersecurity, and other hot topics at the SEC and FINRA’s 2017 National Compliance Outreach Program for Broker-Dealers. The panelists, including SEC Commissioner Michael Piwowar, FINRA President and CEO Robert Cook, and Susan Axelrod, the Executive Vice President…
FINRA’s 2017 Annual Regulatory and Examination Priorities
On Jan. 4, 2017, FINRA released its 12th annual Regulatory and Examination Priorities Letter in which it identifies its areas of examination focus for 2017, recurring challenges faced by firms, and possible risks impacting the financial sector. FINRA’s 2017 exam priorities do not appear to be revolutionary or new relative to its pronouncements during the…
FINRA Sends Targeted Exam Letter Concerning the Sale of Non-Traded Business Development Companies
FINRA recently sent a sweep letter (or targeted exam letter) to select broker dealers, inquiring about those firms’ sale of non-traded Business Development Companies (BDCs). BDCs are SEC-registered investment companies (usually closed-end funds) that pool investor funds in a debt or equity portfolio (typically of small- or medium-sized companies), with the objective of generating income…
FINRA Announces Rule 2273, Requiring Broker’s New Firm to Send “Educational Communication” to Broker’s Customers Before Transfer of the Customer’s Assets to the New Firm
FINRA has issued a regulatory notice (RN 16-18) regarding new Rule 2273, which requires member firms, when hiring a new broker from the competition, to send an “educational communication” to that broker’s customers if and when those customers move or seek to move their assets to the hiring firm. The new rule, which was recently…
Not Every Broker-Dealer is an EB-5 Broker-Dealer
Nearly all U.S. broker-dealers are members of the Financial Industry Regulatory Authority (FINRA). FINRA regulates, and provides oversight and guidance for its member firms. When a broker-dealer becomes a FINRA member, they enter into a membership agreement which, among other things, specifies which financial products and services the broker-dealer is permitted to offer to its…
SEC and FINRA Name EB-5 as a Priority in 2016
Earlier this month, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) each published their 2016 exam priorities letters. Each agency publishes an exam priority letter annually in which they identify topics of examination focus for the coming year, recurring challenges faced by firms, and perceived areas of heightened risk…