The Division of Corporation Finance of the U.S. Securities and Exchange Commission (“SEC”) recently issued new interpretive guidance (the “Staff Guidance”) that provides helpful clarity for private fund issuers seeking … Continue reading SEC Staff Guidance Eases Accredited Investor Verification Under Rule 506(c)
The Financial Industry Regulatory Authority (FINRA) has proposed a new rule, FINRA Rule 3290 – Outside Business Requirements (Proposed Rule), to simplify and reduce unnecessary regulatory burdens related to the … Continue reading FINRA Proposes Rule 3290 to Streamline Oversight of OBAs and PSTs
In August 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a new rule (“RIA AML Rule”) extending anti-money laundering (“AML”) requirements to certain investment advisers. The RIA AML Rule aims … Continue reading AML Compliance for Investment Advisers: Essential Steps to Meet the 2026 Deadline
Overview The Financial Industry Regulatory Authority (FINRA), while not a federal agency, operates under the supervision of the United States Securities and Exchange Commission (SEC). As the SEC aligns more … Continue reading Deregulation, Oversight and FINRA: A New Regulatory Era?
Introduction The Corporate Transparency Act (CTA) is one of the most significant regulatory changes affecting U.S. businesses in recent years. It was designed to combat financial crimes such as money … Continue reading Corporate Transparency Act – New BOA Filing Deadline
In April of 2024, the U.S. Department of Labor (DOL) released the Retirement Security Rule (Rule) which sought to broaden the definition of an investment advice fiduciary for purposes of … Continue reading DOL Rule in Limbo, But Not Best Interest Standard
Regulatory Notice 24-02 (“Notice”) was recently issued by the Financial Industry Regulatory Authority (“FINRA”), wherein it announced the adoption of FINRA Rules 3110.18 and 3110.19 (“Rules”), and the end of … Continue reading FINRA Updates Remote Branch Inspection Guidance
Overview The Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 24-02 (“Notice”) to announce the adoption of FINRA Rules 3110.18 and 3110.19 (“Rules”), which provides guidance on the supervision of … Continue reading FINRA Issues Guidance Regarding Residential Supervisory Locations
While state registered investment advisers are subject to the Corporate Transparency Act (“CTA” or “Act”) based on your organizational structure, it will also have a significant impact on the reporting … Continue reading Impact of Corporate Transparency Act on Broker-Dealers and Investment Advisers
The Securities and Exchange Commission (“SEC”) adopted new rules under the Investment Advisers Act of 1940 (“Advisers Act”) that are designed to protect investors who invest in private funds by … Continue reading Its Official, RIA Annual Compliance Reviews Must be Documented in Writing
The SEC Division of Examinations recently issued a Risk Alert addressing compliance issues that are faced by investment advisers that have recently registered with the SEC (“newly-registered advisers”). While the … Continue reading Observations from SEC Examinations of Newly Registered Advisers
Overview The Securities and Exchange Commission (“SEC”) is proposing a new rule (“proposed safeguarding rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) to address how investment advisers safeguard … Continue reading SEC Proposes New Custody Rule
The Consolidated Appropriations Act, 2023 (H.R. 2617) was signed into law on December 2022 by President Biden. H.R. 2617 included a new Exchange Act Section 15(b)(13) (the “Act”), which codified … Continue reading New M&A Broker Exemption Now Effective
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
The U.S. Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority (“FINRA”) and the North American Securities Administrators Association (“NASAA”) recently released a new resource intended to assist … Continue reading Senior Safe Act Training Resources Available
In January 2021, the Department of Labor (“DOL”) announced a rule addressing the distinction between employees and independent contractors (“Independent Contractor Rule”) under the Fair Labor Standards Act (“FLSA”). The … Continue reading DOL Withdraws Proposed Independent Contractor Rule
The New York Investment Advisory Act (the “Rule”) has been amended, and effective February 1, 2021, New York requires investment adviser representatives (“IARs”) who render investment advice or act as … Continue reading Agent Registration Required for New York Investment Adviser Representatives
As noted in our earlier articles, the reforms made to the Investment Advisers Act of 1940 (“Act”) that were adopted by the Securities and Exchange Commission (“SEC”) to modernize rules … Continue reading New RIA Marketing Rule Impacts Solicitor Relationships
As noted in our earlier articles, the Securities and Exchange Commission (“SEC”) adopted reforms under the Investment Advisers Act of 1940 (“Act”) to modernize rules that govern investment adviser advertisements … Continue reading Testimonials and Endorsements – Impact of the New RIA Marketing Rule
As previously noted, the Securities and Exchange Commission (“SEC”) adopted reforms under the Investment Advisers Act of 1940 (“Act”) to modernize rules that govern investment adviser advertisements and payments to … Continue reading Overview of Advertising – Impact of the New RIA Marketing Rule
On December 22, 2020, the Securities and Exchange Commission (“SEC”) finalized reforms under the Investment Advisers Act of 1940 (“Act”) to modernize rules that govern investment adviser advertisements and payments … Continue reading SEC Adopts New RIA Marketing Rule
The Securities and Exchange Commission (“SEC”) has proposed a conditional exemption from broker registration requirements for certain “finders” who assist issuers with raising capital in private markets from accredited investors. … Continue reading SEC Proposes Exemption for Finders
Proposed Amendments The Securities and Exchange Commission (the “SEC”) has proposed amendments to Section 13(f) of the Securities Exchange Act of 1934 (“Form 13F”). The most significant amendment change would … Continue reading SEC Proposes Amending Form 13F Reporting Thresholds
The Securities and Exchange Commission (“SEC”) has adopted amendments to update the definition of “accredited investor” in the SEC’s rules, and the definition of “qualified institutional buyer” in Rule 144A … Continue reading Accredited Investor Definition Updated by SEC
The Securities and Exchange Commission (“SEC”) recently issued a Risk Alert addressing client account credential compromises against SEC-registered investment advisers (“advisers”) and brokers and dealers (“broker-dealers,” and together with advisers, … Continue reading Credential Compromise Risk Increasing for Client Accounts
Payroll Protection Program (PPP) Loans Recent guidelines issued by the Securities and Exchange Commission (SEC) have again shed light on the fact that broker-dealers and investment advisers address disclosure issues … Continue reading PPP Loans Create Divergent Disclosure Paths for Brokers and Advisers
Broker-dealers and investment advisers are now subject to Multi-Factor Authentication (MFA) on the Firm Gateway as a result of the security protocols being implemented by the Financial Industry Regulatory authority … Continue reading FINRA Implements Multi-Factor Authentication for Firm Gateway
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)
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)
The Financial Industry Regulatory Authority (“FINRA”) has announced a proposed rule to limit any associated person of a member firm who is registered with FINRA (each a “registered person”) from … Continue reading FINRA Proposes Rule Restricting Registered Reps Being Named a Beneficiary, Executor or Trustee
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)
The Securities and Exchange Commission (SEC) announced that it has scheduled an open meeting on June 5 to consider pending rulemaking related to the relationship of broker-dealers and investment advisers … Continue reading Release of Regulation Best Interest to be Considered by SEC on June 5
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
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
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
The Financial Industry Regulatory Authority (“FINRA”) has implemented a 529 Plan Share Class Initiative (“529 Initiative”) to promote member firms’ compliance with the rules governing recommendations of 529 savings plans … Continue reading FINRA Focuses on Self-Reporting Violations in 529 Plan Share Class Initiative
The Financial Industry Regulatory Authority (FINRA) has released its 2019 Risk Monitoring and Examination Priorities Letter, which highlights new priorities as well as identifies areas of ongoing concern that FINRA … Continue reading 2019 Risk Monitoring and Examination Priorities Letter Released by FINRA
The Financial Industry Regulatory Authority’s (“FINRA”) 2018 Examination Findings Report regarding broker-dealer (“firms” or “members”) examinations made it clear that it had targeted due diligence for private placements as a … Continue reading FINRA’s 2018 Examination Findings Report Targets Private Placement
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
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) has released its 2019 examination priorities. OCIE publishes its exam priorities annually to promote transparency of its examination … Continue reading SEC Releases 2019 Examination Priorities
As a result of the federal government shutdown, if you would like Division of Corporation Finance of the Securities and Exchange Commission (Corp Fin) to consider a request for acceleration … Continue reading Government Shutdown Impacts SEC Operations
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
In a move to align the regulatory requirements with current technology, the Financial Industry Regulatory Authority (FINRA) recently filed a proposed rule change with the SEC regarding the utilization of … Continue reading Use of Electronic Signatures Proposed in FINRA Rule Amendment
The Securities and Exchange Commission (SEC) recently adopted rules and amendments designed to promote research on investment funds. These funds include mutual funds, exchange‑traded funds, registered closed-end funds, business development companies, … Continue reading SEC Adopts Rules Promoting Research on Investment Funds
The Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert to provide investment advisers with information concerning the most common deficiencies the … Continue reading OCIE Issues Guidance on Cash Solicitation Rule for RIAs
The Securities and Exchange Commission (“SEC”) recently issued an investigative report cautioning that public companies should consider cyber threats when implementing internal accounting controls, especially where the movement of assets … Continue reading Stronger Internal Accounting Controls Needed to Fight Cyber Threats
To minimize the potential for a conflict of interest with former FINRA employees representing persons to the Financial Industry Regulatory Authority (“FINRA”), FINRA is filing a proposed rule to prohibit: Any … Continue reading FINRA Employees to be Subject to New Post-Employment Conflict of Interest Rule
The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have restated the importance of broker/dealers doing due diligence on third-party service providers, especially where the firm … Continue reading SEC Staff Issues Guidance on Third-Party Recordkeeping Services
To address recent comments regarding the concept that the Securities and Exchange Commission (“SEC”) is de facto rulemaking based on the views of staff, SEC Chairman Jay Clayton issued a … Continue reading SEC Chairman Clayton Addresses SEC Staff Views
The Financial Industry Regulatory Authority’s (‘FINRA”) restructured qualification examination program will become effective on October 1, 2018, and it will then require that all new representative-level applicants be required to take a … Continue reading FINRA Restructures Qualification Examination Program
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
The Municipal Securities Rulemaking Board (“MSRB”) is seeking comments from regulated entities and other stakeholders about draft answers to frequently asked questions (“FAQs”) addressing the use of social media in … Continue reading MSRB Seeks Comments on the Use of Social Media
The Supreme Court decision in Lucia v. SEC that the in-house SEC administrative law judges (“ALJ”) were not properly appointed and put in office has resulted in the Securities and … Continue reading ALJ Decision Results in SEC Retrying Enforcement Actions
The Sanction Guidelines were revised by FINRA to instruct adjudicators in the disciplinary process to consider customer-initiated arbitrations that result in adverse arbitration awards or settlements when assessing sanctions. Thus, … Continue reading Sanction Guidelines Revised by FINRA
The Securities and Exchange Commission (SEC) has proposed for public comment several amendments to the SEC’s rules implementing its whistleblower program. The whistleblower provisions of the Securities Exchange Act of … Continue reading SEC Proposes Amendments to Whistleblower Rule
Financial Industry Regulatory Authority (FINRA) Regulatory Notice 17-30 noted that the Securities and Exchange Commission (SEC) had approved new registration and qualification rules for FINRA, including that members are required … Continue reading FINRA Requires Principal Financial Officer and Principal Operations Officer
The Securities and NYSE Commission (SEC) has published notice to solicit comments on a proposed rule change from the New York Stock NYSE LLC (NYSE) to amend Rule 2 to … Continue reading NYSE Proposes to Drop FINRA Membership Requirement
FINRA recently announced the Department of Enforcement’s new structure, which marks the completion of the final phase of the integration of FINRA’s enforcement functions, a process that began in July … Continue reading New Enforcement Structure Announced by FINRA
The Code of Arbitration Procedure for Customer Disputes (Customer Code) and the Code of Arbitration Procedure for Industry Disputes (Industry Code, and together with the Customer Code, the Codes) have … Continue reading Simplified Arbitration Approved by SEC
The Financial Regulatory Authority (“FINRA”) recently issued Regulatory Notice 18-20, which encouraged member firms to provide notification if either the broker-dealer or their associated persons or affiliates were engaging in, … Continue reading FINRA Encourages Disclosure of Activities in Digital Assets
The Office of Compliance Inspections and Examinations (“OCIE”) recently issued a Risk Alert regarding Best Execution The alert was targeted to investment advisers (“advisers”), investors and other market participants with … Continue reading SEC Issues Best Execution Risk Alert
FINRA is making enhancements to its disclosure review process that will permit firms to rely on FINRA’s background investigation and verification process for purposes of compliance with the requirement to … Continue reading FINRA Provides Background Investigation of Public Financial Records
Comments are due to the Securities and Exchange Commission (SEC) by August 18, 2018 on the proposed Regulation Best Interest. This is a significant proposal as it is the SEC’s … Continue reading Regulation Best Interest Update
The 2018 Regulatory and Examination Priorities Letter is an affirmation that the coming year will bring both continuity and change in FINRA’s regulatory programs. The continuity comes, first in the … Continue reading FINRA 2018 Regulatory and Examination Priorities Letter
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
FINRA is seeking comment on proposed amendments to FINRA Rule 4521 (Notifications, Questionnaires and Reports) that would require specified member firms to notify FINRA no more than 48 hours after … Continue reading FINRA Requests Comments on Proposed Amendments to FINRA Rule 4521
The FINRA Codes of Arbitration and Mediation Procedure (“Codes”) permits non-attorney representation of clients in securities arbitration and mediation subject to certain exceptions. FINRA is currently conducting a review of … Continue reading Is There a Place for Non-Attorney Representation Firms in Arbitration?
The Financial Industry Regulatory Authority (FINRA) announced it has fined J.P. Morgan Securities, LLC $1.25 million for failing to conduct timely or adequate background checks on approximately 8,600, or 95 … Continue reading Firm Fined $1.25 Million for Failure to Run Adequate Background Checks
Merrill Lynch recently claimed that its participation in the Protocol for Broker Recruiting (“broker protocol”) only applies to brokers who do not carry the “vice-president” or above title – which is … Continue reading Broker Protocol Under Attack by Wall Street
The Department of Labor (DOL) issued a release on Monday and announced that the full implementation of key provisions of the DOL fiduciary rule would be extended 18-months. To that end, … Continue reading Fiduciary Rule Implementation Delayed 18 Months
FINRA’s responded to industry feedback on the inspection process for branch offices. Based on Rule 3110 (the Supervision Rule), each firm to currently required to establish and maintain a system … Continue reading FINRA Requests Comments on Proposal for Remote Inspections of Branch Offices
In support of the Municipal Securities Rulemaking Board’s (“MSRB”) ongoing efforts to more fairly and equitably assess fees among regulated entities, the MSRB has filed a rule amendment to MSRB Rule A-11, … Continue reading MSRB Fees to Increase for Municipal Advisors
After two years of public comments and discussion, the U.S. Department of Labor (“DOL” or “Department”) released the fiduciary rule in its final form On April 6, 2016. Under the … Continue reading Current Status of the DOL Fiduciary Rule
At the September FINRA Board of Governors meeting, the Board authorized publishing for comment two proposed rulemaking items. One would permit firms to use technology to conduct remote inspections of … Continue reading FINRA Board Approves Rule Proposals on Low Risk Branch Exams and Expanded BrokerCheck Discosures
The Financial Industry Regulatory Authority, Inc. (“FINRA”) has announced that it is filing with the Securities and Exchange Commission (“SEC” or “Commission”), a proposed rule change to amend Section 13 of … Continue reading Communications Submitted for Review by FINRA Face Increased Review Fees
The Securities Investor Protection Corporation (SIPC) and the Financial Industry Regulatory Authority (FINRA) recently announced a joint services agreement that was designed by the agencies to ease the reporting burdens and … Continue reading SIPC / FINRA Streamline Broker/Dealer Reporting Process
The Financial Industry Regulatory Authority (FINRA) has adopted a new electronic Form 211 for purposes of compliance with FINRA Rule 6432 (Compliance with the Information Requirements of SEA Rule 15c2-11). … Continue reading FINRA’s Adopts Electronic Form 211 for FINRA Rule 6432 Compliance
The Financial Industry Regulatory Authority (FINRA) has issued a Compliance Vendor Directory for its members as a new resource for firms searching for vendors that offer compliance-related products and services. … Continue reading FINRA Offers Compliance Vendor Directory
The Securities and Exchange Commission (“SEC”) announced the agenda for the next meeting of its Advisory Committee on Small and Emerging Companies. The committee will discuss the Sarbanes-Oxley Act auditor … Continue reading SEC Released Agenda for Meeting of Advisory Committee on Small and Emerging Companies
The US Securities and Exchange Commission (“SEC”) issued an update to the guidance previously issued in the Staff Response to Questions about the “pay to play” rule (Investment Advisers Act … Continue reading Pay to Play Guidance Issued Related to CAB Broker/Dealers
In Form ADV and Investment Advisers Act Rules, Advisers Act Release No. 4509, the Securities and Exchange Commission (“SEC”) adopted amendments to Form ADV that have a compliance date of October 1, … Continue reading SEC Releases Updated Instructions for Form ADV Filings with Incomplete Information
The Public Company Accounting Oversight Board (PCAOB) has adopted new rules and amendments to auditing standards (collectively, the “proposed rules”) to make the auditor’s report more informative and relevant to … Continue reading PCAOB Adopts New Rules for Audit Reports
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
The Securities and Exchange Commission ( “SEC”) is proposing to amend the definition of a venture capital fund (rule 203(l)-1) and the private fund adviser exemption (rule 203(m)-1) under the Investment Advisers … Continue reading SEC Proposes Amendment to Investment Advisers Act to Address FAST Act
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
The Financial Industry Regulatory Authority has released guidance to help securities firms implement a new rule requiring enhanced price disclosure to retail customers for trades in corporate and agency bonds. … Continue reading FINRA Posts Guidance on Disclosure to Retail Customers
The Securities and Exchange Commission (SEC) approved FINRA Rule 2030 (Engaging in Distribution and Solicitation Activities with Government Entities) and 4580 (Books and Records Requirements for Government Distribution and Solicitation Activities) … Continue reading SEC Approves New FINRA Pay-To-Play Rules
The California Department of Business Oversight (“Department”) has modified Section 25206.1 of the California Corporation’s Code (“Code”) which provides a broker-dealer registration exemption for the payment of finder fees to … Continue reading California Modifies Exemption for Payment of Finder Fees
The Securities and Exchange Commission (SEC) charged Alpine Securities Corporation, a Salt Lake City-based clearing firm, with securities law violations related to its anti-money laundering program through its alleged practice … Continue reading SEC Charges Clearing Firm with Failing to Comply With Anti-Money Laundering Laws
The Financial Industry Regulatory Authority (FINRA) is amending FINRA Rule 4530 by adding a new Rule 4530 Problem Code to address changes the United States Department of Labor (DOL) has … Continue reading FINRA Revises Rule 4530 to Address New DOL Fiduciary Rule
In an op-ed published last week in The Wall Street Journal, Labor Secretary Alexander Acosta stated that the Department of Labor (“DOL” or “Department”) will not delay the June 9th … Continue reading DOL’s June 9th Compliance Date for the Fiduciary Rule Won’t Be Delayed
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
In light of trends in emerging technologies and communications innovations, FINRA has issued new guidance regarding the application of FINRA rules governing communications with the public to social media and … Continue reading FINRA Issues New Guidance on Social Media and Digital Communications
The Securities and Exchange Commission (“SEC”) has adopted an amendment to shorten the standard settlement cycle for most broker-dealer securities transactions by one business day (“T+2”). Currently, the standard settlement … Continue reading SEC Adopts T+2 Settlement Cycle for Securities Transactions
FlNRA Rule 3210 – Accounts at other Broker-Dealers and Financial Institutions (the “Rule”) was approved by the SEC in 2016 and became effective April 3, 2017. As approved, the new … Continue reading FINRA Rule 3210 – Accounts at Other Broker-Dealers
In an attempt to collect more information on private placement activity, the Financial Industry Regulatory Authority (“FINRA”) has updated the private placement filer form that member firms must use to … Continue reading FINRA Updates Private Placement Filer Form
The Securities and Exchange Commission (“SEC”) has recently noted that there have been reports of malicious emails sent to some EDGAR filers that appear to be part of a phishing campaign … Continue reading Phishing Scam Targeting EDGAR Filers
The Supreme Court ruled that the Securities and Exchange Commission’s power to require the disgorgement of illegally obtained profits can only be applied to funds obtained up to five years … Continue reading Supreme Court Decision limits SEC Disgorgement Powers
Standardizing cybersecurity regulations is becoming more important as the focus on cybersecurity continues to spur new laws, regulations and guidelines. Just recently Treasury Secretary Steven Mnuchin noted that since the safety … Continue reading Standardizing Cybersecurity Regulations
On February 27, 2017, the Financial Crimes Enforcement Network (FinCEN) announced the assessment of a $7 million civil money penalty (CMP) against Merchants Bank of California (“Merchants”) in Carson, CA, … Continue reading FinCEN Penalizes California Bank for AML Violations