The SDDco Client Update
The SDDco Client Update is an action oriented email prepared in-house, tailored to client needs, and sent as an adjunct to our online newsletter. Verified newsletter subscribers receive our Client Update once each month.
The SDDco Client Update is intended to provide general information only. It is not intended as, and should not be taken as, financial, tax, accounting, legal, consulting or any other type of advice specific to you or your firm. Users of the SDDco Client Update should not act or refrain from acting on the basis of information provided on the sddco.com website. Always check with your accountant and/or attorney.
A recent SEC no-action letter offers temporary relief to broker-dealers that have requested a temporary exemption under the amended Customer Protection Rule 15c3-3. Customer Protection Rule 15c3-3(e) Amendments adopted under Rule 15c3-3(e) of the Securities Exchange Act of 1934, effective October 21, 2013, in part require the following: New Account Setup: “Carrying broker dealers” (those holding proprietary accounts for
The Commodity Futures Trading Commission (CFTC) staff members have laid out data security practices for its regulated entities. This guidance will help firms comply with industry regulations that protect customer financial information. Advisory 14-21 effects futures commission merchants( FCMs), commodity trading advisers (CTAs), commodity pool operators (CPOs) , introducing brokers (IBs), retail foreign exchange dealers (RFEDs), swap
Mutual funds often operate as multi-manager funds—where a fund’s primary adviser oversees sub-advisers acting as the day-to-day portfolio managers. The Investment Management Division of the Securities and Exchange Commission (IMD Staff) issued guidance for multi-manager funds regarding if and when to get shareholder approval for aggregate rate changes. Main Message Multi-manager structures generally do not need to
FINRA is working towards trimming and reshaping governance to better fit the activities of limited broker-dealer categories. Last week, FINRA issued Regulatory Notice 14-09 seeking feedback on a proposed set of rules for the “limited corporate financing broker” (LCFB). While an LCFB would be subject to the FINRA By-Laws and core FINRA rules, other rules
The Foreign Account Tax Compliance Act of 2010 (FATCA), targeting non-compliance by taxpayers with foreign accounts, requires online registration and the reporting of foreign financial assets. Per IRS Issue 2014-5, the revised final FATCA regulations are posted to the Federal Register. Also, FATCA forms and instructions for 2014 are now available at IRS.gov, including the following: • Form
The Municipal Securities Rulemaking Board (MSRB) invites comment on a proposal to establish—for the very first time—explicit best-executions standards for municipal securities dealers. The best-execution proposal supports MSRB market transparency plans started in 2012. Draft G-18 Draft Rule G-18: Execution of Transactions (“Draft G-18”) would require brokers, dealers, and municipal securities dealers (“dealers”) to use