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.
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On November 18th, the SEC announced a proposed rule to add transparency and regulatory oversight of alternative trading systems (ATSs). This rule will focus on ATSs’ off-exchange equity deals sometimes called “dark pools.” The proposed rule would mandate firms using ATS to file detailed disclosures about business activities that may present conflicts of interest between
The Financial Accounting Standards Board (“FASB”), the rulemaking board for U.S. accounting, voted to proceed with a new accounting standard that would require companies and other organizations to include lease obligations on their balance sheets. Standards Timeline The final Accounting Standards Update (“ASU”) is expected to be published in early 2016; however, the standard will
FINRA’s free one-hour webinar for small firms addresses “building an effective cybersecurity program with limited resources.” Tune in for best data protection practices and ways to apply the National Institute of Standards and Technology (“NIST”) framework. Topics Covered Overview of NIST Framework Role of compliance in addressing cyber risks Factors for developing a cybersecurity program Focus
FINRA has adopted new Rule 4380, which grants FINRA authority to designate firms to participate in FINRA’s business continuity and disaster recovery testing under Regulation Systems Compliance and Integrity (“SCI”). The rule becomes effective on November 30, 2015. The tests will be conducted once per year. Background on New Rule 4380 On November 19, 2014,
FINRA to Require Electronic Submission of Subordination Approval Requests FINRA is launching a new electronic platform on Firm Gateway for firms to submit all new requests for approval of proposed subordinated loan agreements and secured demand note agreements (referred to as subordinations), including renewals of existing agreements. FINRA will no longer accept new requests
In 2013, the SEC added a requirement for broker-dealers to identify their independent public accountant. Pursuant to amended paragraph (f)(2) of SEA Rule 17a-5, broker-dealers must file a statement with the SEC and FINRA regarding this information. The deadline for the yearly filing is December 10th. If the broker-dealer filed a “Statement Regarding Independent Public
By March, NFA member firms will have to draft and enforce written policies and procedures to secure their customer data and access to their electronic systems. Backfill The CFTC recently approved the NFA’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 entitled Information Systems Security Programs. The “Cybersecurity Notice,” covering all NFA membership categories—futures commission
New rulemaking governing investment adviser examinations is advancing on the mission list of the Securities and Exchange Commission (“SEC”). According to David Grim, Director of the SEC’s Division of Investment Management, in addition to Form ADV changes the “Division” is working on an initiative concerning potential rulemaking for the third-party compliance reviews of registered investment
The SEC has now adopted final regulations on crowdfunding, mandated by the JOBS Act Title III, enabling retail investors to buy within limits unregistered securities online. To offer these unregistered securities, private companies eligible for the crowdfunding exemption must use an intermediary—specifically an SEC registered broker-dealer or a new category: an SEC registered ”funding portal.”
In a landmark decision, on October 30, 2015, the SEC adopted final equity crowdfunding rules, mandated by Title III of the JOBS Act, giving smaller firms a big boost in their ability to raise funding through the sale of securities online. Till now, securities investments could not be gotten from the average Joe…rather limited to