The SEC recently voted to adopt amendments to Rule 606 of Regulation NMS (the “Final Rule”) that expand broker-dealers’ disclosure obligations with regard to how they handle investors’ orders. Specifically, the Final Rule requires broker-dealers, beginning May 20, 2019, (i) to provide, upon request, individualized reports in a
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The Federal Reserve has finalized a new supervisory ratings system for large financial institutions (LFIs), discussed in our visual memorandum here.  The new LFI rating system, which reflects the three core areas of focus in the Federal Reserve’s current LFI supervisory framework—capital, liquidity and governance and controls—is
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The CFTC unanimously approved Final Rule amendments on August 21, 2018 to the regulations governing chief compliance officer (“CCO”) duties and annual compliance reporting requirements for FCMs, swap dealers and MSPs (“Registrants”). These amendments are the first substantive rule amendments to be adopted under Chairman Giancarlo’s
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On May 11, 2018, the customer due diligence rule, 31 C.F.R. § 1010.230 (the “CDD Rule”), issued by the Financial Crimes Enforcement Network (“FinCEN“) became applicable two years after it was issued.  The CDD Rule added a new requirement for covered financial institutions to identify,
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As expected, the DOL has officially delayed the applicability date of the full requirements of the Best Interest Contract (BIC) Exemption, Principal Transactions Exemption and PTE 84-24 by 18 months, from January 1, 2018 to July 1, 2019.  Our post from earlier this year described which requirements of these exemptions
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The U.S. banking agencies (the Federal Reserve, OCC and FDIC) have delayed the last phase of the U.S. Basel III capital rules’ transition provisions relating to certain deductions from capital and limitations on the recognition of minority interests, which were scheduled to become effective January 1, 2018, for banking organizations
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Many have commented on the suit filed last week challenging the CFPB’s arbitration rule, but few have considered what impact, if any, the suit could have on the fast-approaching compliance date of March 19, 2018.

As a reminder, the Chamber of Commerce and other trade associations filed a long-anticipated suit
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Yesterday afternoon, the CFPB issued a final rule that, once it becomes effective, is designed to prohibit providers of certain consumer financial products or services from using pre-dispute arbitration clauses to bar consumers from participating in class action lawsuits.  Although covered providers will still be permitted to include mandatory arbitration
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Early press accounts of President Trump’s regulatory moratorium are highly misleading for financial sector regulations.  On Friday, White House Chief of Staff Reince Priebus issued a memorandum (the “Priebus Memo”) to the heads of executive departments and agencies instructing them to, among other things, stop submitting regulations for publication in
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