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SEC Issues Risk Warning on Whistleblowing

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a Risk Alert on October 24, 2016, regarding the staff’s examination of broker-dealers for compliance with the Dodd-Frank whistleblower provisions.  The warning notes that the staff will review compliance manuals, codes of ethics, employment agreements and severance agreements, among others, to see whether... Read more »

SEC Proposes Reducing Settlement by One Day to T+2

The Securities and Exchange Commission (the “SEC”) has proposed to amend its Rule 15c6-1(a) to require broker-dealers to settle most non-exempt securities in T+2 instead of T+3, although shorter settlement is possible.  See proposal, here. Comments are due by December 5, 2016.  There seems to be little opposition to the basic shortening, which comes some... Read more »

FINRA to Require TRACE Reports on Treasury Transactions

The Securities and Exchange Commission (the “SEC”) has approved the Financial Industry Regulatory Authority’s (“FINRA”) plan to require, as of July 10, 2017, the reporting by FINRA member firms of transactions in U.S. Treasuries to the Trade Reporting and Compliance Engine (“TRACE”).  See FINRA Regulatory Notice 16-39, October 2016, here.  The rules will apply to... Read more »

NY Department of Financial Services Proposes New Cybersecurity Rules

In September of 2016, the NY Department of Financial Services (the “DFS”) proposed rules to require anyone operating under the NY banking law, insurance law or financial services law (a “Covered Entity”) to adopt a cybersecurity program and a cybersecurity policy, to appoint a chief information officer (a “CIO”), to do penetration and vulnerability testing,... Read more »

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