On July 30, 2024, the SEC announced it had reached a settlement agreement with Western, a dually registered investment adviser and broker-dealer providing investment advice and brokerage services to retail customers, for allowing a former representative to engage in a strategy of day-trading options that the SEC contended was not in retail customers’ best interests.…

  1. Increasing Regulatory and Enforcement Risk – As we enter an election year, and considering the government’s aggressive hiring, financial institutions can expect to see increased activity by federal and state regulators and enforcement authorities, including the DOJ, SEC, CFTC, CFPB, FINRA, and State AGs. Jurisdictional creep continues to be of concern. We expect key rulings
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On July 26, 2023, the Securities and Exchange Commission (SEC) adopted the long-awaited final rule requiring that public companies disclose information about cybersecurity incidents within four business days of determining the incident is material. GT wrote about the proposed rule shortly after it was released in March 2022. For context, Commissioner Caroline Crenshaw noted, in…

On Jan. 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint statement (Joint Statement) that reiterates prior crypto-related guidance and highlights crypto-asset risks to banking organizations. The Joint Statement follows a…

On Sept. 29, 2022, the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 22-20, alerting members to changes to the Sanctions Guidelines (Guidelines), effective immediately. The notice discusses changes varying from new fine ranges/minimums, additional guidelines, and non-monetary sanctions.

Continue reading the full GT Alert.

Federal regulatory agencies are closely monitoring crypto-asset developments and banking organizations’ participation in the crypto-asset industry. This GT Alert covers the guidance issued by the FDIC, CFPB, and the Federal Reserve which especially highlights the risks associated with bank and non-bank partnerships.

Continue reading the full GT Alert.

The Appointed Representatives Regime (ARR), a well-known and important feature of the UK regulatory landscape, enables certain businesses – Appointed Representatives (ARs) – to conduct regulated activities without having to be authorised by the Financial Conduct Authority (the FCA). The FCA is proposing significant new rules and guidance that seek in the main to increase…

On Oct. 23, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (FRB) (FinCEN and the FRB collectively, the Agencies), issued a joint notice of proposed rulemaking (Proposed Rule) that would amend the Recordkeeping Rule and Travel Rule regulations issued under the

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On Sept. 25, 2020, the SEC issued a No-Action Letter to FINRA, in response to a previously issued Joint Statement by the SEC and FINRA. This No-Action Letter detailed how broker-dealers could operate alternative trading systems that trade digital assets without garnering enforcement action from the SEC for not meeting the custody requirements required under…

On Thursday, Aug. 20 at 11 a.m. EST, join GT Shareholders Carl Fornaris and Oscar Stephens for a complimentary webinar on the status of the phaseout of LIBOR, current trends and action plans. With less than 18 months to go until the expected date of discontinuation of LIBOR by the end of 2021, the program…