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.
In November 2016, the staff of the SEC’s Division of Investment Management (“Division Staff”) released an IM guidance Update on Investment Advisers Reliance on Predecessor Registrations. This guidance covers how and when an entity may rely on a predecessor’s registration as an SEC registered investment Adviser (“RIA”). Please note that Division Staff guidance while helpful
The SEC approved a national market system (NMS) plan to create a single, comprehensive database—the consolidated audit trail (CAT)—to enable regulators to better track all trading in the U.S. equity and options markets. The NMS plan will detail how self-regulatory organizations (SROs) and broker-dealers (BDs) will record and report information, and explains how the data
An SEC No Action Letter to SIFMA, dated November 8, 2016, assures the Division of Trading and Markets staff (“Division”) would not recommend enforcement action to the SEC (under SEA Rule 1 Sc3-1) if a broker-dealer treats the asset and liability arising from an operating lease in the manner described below. The FASB Trigger The
On October 26, 2016, the SEC adopted final rules to update how companies can raise money to fund their businesses through intrastate and small offerings. According to SEC Chair Mary Jo White, “These final rules, while continuing to provide investor protections, update and expand the capital raising avenues for smaller companies, allowing them to more
On August 25, 2016, the SEC approved new FINRA rules governing political contribution matters tied to the award of advisory business. Per FINRA Regulatory Notice 16-40 ~ Political Contributions, the FINRA “Pay-to-Play Rules” aim to regulate the pay-to-play activities of FINRA member broker-dealers compensated for engaging in distribution or solicitation activities on behalf of investment
The payment deadline for the 2017 Renewal Program of Broker-Dealer, Investment Adviser Firm, Agent and Investment Adviser Representative, and Branch Renewals is December 16, 2016. As of November 14, 2016, FINRA will make the online Preliminary Statements available to all firms in E-Bill. Key Renewal Dates: October 24, 2016: Firms could begin submitting post-dated Form
As part of its next strategic planning cycle, starting January 2017, the Municipal Securities Rulemaking Board (MSRB) is seeking public input on its long-term priorities to help guide the strategic direction of the organization. Request for Comment The MSRB is seeking public comment regarding its long-term priorities and initiatives as they relate to core activities
The SEC’s Office of Investor Education and Advocacy issued an Investor Alert to warn about investment schemes in which fraudsters send fake Forms 4 to investors claiming the investor paid for the purported purchase of shares. Fraudsters may pose as brokers pretending to sell pending IPO or pre-IPO shares of well-known companies: They may use official looking forms that
The SEC has approved eased communication filing requirements for FINRA broker-dealers (“firms”) related to registered investment company (RIC) shareholder reports, non-predictive retail communications, ranking and comparison backup material for communications holding fund performance, investment analysis tool templates, and bond mutual fund volatility ratings. The following rules were impacted: FINRA Rule 2210 (Communications with the Public)