Rule change related to Registration and Continuing Education

As summarized below, FINRA recently filed with the SEC a proposed rule change to adopt, with amendments, the NASD and Incorporated NYSE rules relating to qualification and registration requirements as FINRA rules in the Consolidated Rulebook. The proposed rule change also restructures the current representative-level qualification examinations and creates a general knowledge examination and specialized knowledge examinations.  In addition, the proposed rule change amends the Continuing Education (“CE”) requirements.

Registration Requirements

FINRA has adopted registration requirements to ensure that associated persons attain and maintain specified levels of competence and knowledge pertinent to their function.  The current FINRA registration rules include both NASD rules and rules incorporated from the NYSE. Read More…

Identity Theft Red Flags Rule

The CFTC and the SEC are jointly issuing final rules and guidelines to require certain regulated entities to establish programs to address risks of identity theft. These rules and guidelines implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which amended the Fair Credit Reporting Act (“FCRA”). First, the rules require financial institutions and creditors to develop and implement a written identity theft prevention program (“Program”) designed to detect, prevent, and mitigate identity theft in connection with certain existing accounts or the opening of new accounts. The rules include guidelines to assist entities in the formulation and maintenance of programs that would satisfy the requirements of the rules. Read More…

FINRA Report Filings for Next Year

FINRA has put out a schedule for its member broker-dealers with the due dates for report filings that are due in 2017 or in the first quarter of 2018. This notice serves as a reminder to help FINRA and SEC registered broker-dealers stay compliant by filing reports on or before their required due dates. Late Read more about FINRA Report Filings for Next Year[…]

MSRB announces Interpretive Notice re: Time of Trade Disclosure

MSRB Rule G-47, as it relates to time of trade disclosure, requires firms to disclose, at or prior to the time of trade, all material information known about the transaction, as well as material information about the municipal security that is reasonably accessible to the market. The MSRB has previously provided interpretive guidance on specific types of information that is material where specific scenarios occur and requires time of trade disclosure, and recently published a notice to state its interpretation that the fact that a municipal security Read More…