Global Financial Regulatory Blog

Tag Archives: FINRA

FINRA Proposes to Relax Communications Rule for Institutional Investors and Qualified Purchasers

The proposed amendment seeks to modify the existing framework of FINRA Rule 2210 to accommodate the use of certain projections and targeted returns. By Stephen P. Wink, Marlon Paz, Gail Neely, Naim Culhaci, Matthew Lee, and Deric Behar On November 13, 2023, the Financial Industry Regulatory Authority (FINRA) filed a proposed rule change with the … Continue Reading

When Are CCOs on the Hook? FINRA Offers Guidance on CCO Liability

Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. By Marlon Q. Paz, John J. Sikora Jr., Stephen P. Wink, and Deric Behar On March 17, 2022, the Financial Industry Regulatory Authority, Inc. (FINRA) published Regulatory Notice 22-10 (Reg. Notice … Continue Reading

FINRA Proposes Amendments to Margin Requirement Rules

The proposed amendments could significantly alter the landscape for extended settlement of securities offerings by expressly limiting the public offering exception for “when-issued” securities to equity IPOs. By: Senet S. Bischoff, Gregory P. Rodgers, Stephen P. Wink, and Naim Culhaci The Financial Industry Regulatory Authority (FINRA) has proposed amendments to its margin requirement rules, which … Continue Reading

SEC Staff Issues No-Action Relief to Broker-Dealers From Reg BI and Form CRS Obligations Related to Certain Family Offices

The no-action relief applies to family offices with at least US$50 million in total assets (Institutional Family Offices) and requires broker-dealers seeking to rely on the relief to establish and maintain specific additional policies and procedures. By Dana G. Fleischman, Stephen P. Wink, Naim Culhaci, and Deric Behar On December 23, 2020, the Staff of … Continue Reading

SEC and FINRA Take Action to Address COVID-19 Impacts

In the wake of COVID-19, the SEC and FINRA are taking steps to support markets and market participants. By Dana G. Fleischman, Stephen P. Wink, and Deric Behar The US Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority, Inc. (FINRA) continue to monitor and address ongoing impacts of COVID-19 to US capital … Continue Reading

FINRA Issues Guidance and Relief in Relation to COVID-19

As COVID-19 disruptions unfold, FINRA has granted temporary relief regarding alternate working arrangements for broker-dealer employees. By Dana G. Fleischman, Stephen P. Wink, Naim Culhaci, and Deric Behar On March 9, 2020, the Financial Industry Regulatory Authority, Inc. (FINRA) issued Regulatory Notice 20-08 to members, reminding FINRA-member broker-dealer firms of their business continuity planning obligations … Continue Reading