United States Regulatory Updates

What Changed

The primary regulatory modification addresses a single-day exception to standard options exercise procedures: CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. OCC Processing Unchanged: The Options Clearing Corporation's proc

What You Need To Do

• *Update Internal Procedures
• *System Configuration
• *Staff Communication
• *Customer Notification
• *Submission Coordination

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

The Section 31 fee rate drops from $27.80 per million dollars to $0.00 per million dollars for covered securities transactions on exchanges and over-the-counter markets, applicable to trade dates (charge dates) of May 14, 2025, or later.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] The assessment on security futures transactions remains unchanged at $0.0042 per round turn transaction.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] FINRA wil

What You Need To Do

• Update internal billing, invoicing, and financial reporting systems to reflect the $0
• Review and adjust any automated fee calculations or client pass-through mechanisms for transactions on or after the effective date
• Contact FINRA's Amanda Rath for finance questions ((240) 386-6637) or SEC's Robert McNamee/Faisal Sheikh for legal/interpretive issues; monitor SEC website for updates
• Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date

Key Dates

References

• [1] ez-xbrl.com
• [2] cooleypubco.com
• [3] sec.gov
• [4] finra.org
• [5] nelsonmullins.com
• [6] infomemo.theocc.com
• [7] sec.gov
• [8] federalregister.gov

What Changed

Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee. Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1–December 31, 2025; monthly invoicing begins for July 2025 transactions. Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect). #

What You Need To Do

• Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
• Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
• Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
• Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
• Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] federalregister.gov
• [4] sec.gov
• [5] finra.org
• [6] findknowdo.com
• [7] catnmsplan.com
• [8] compliance-risk.com

What Changed

Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814] Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic

What You Need To Do

• Registered persons
• Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions

Key Dates

References

• [1] stcusa.com
• [2] nasaa.org
• [3] finra.org
• [4] questce.com
• [5] finra.org
• [6] finra.org

What Changed

Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice] Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice] Overall Timeline Reduction: Full ACATS transfers

What You Need To Do

• Operational Readiness
• Exception Handling
• System Updates
• Contact FINRA/NSCC

Key Dates

References

• [1] ftfnews.com
• [2] finra.org
• [3] advisorfinder.com
• [4] finra.org
• [5] sec.gov
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles). #

What You Need To Do

• Access and reference the 2026 Filing Schedule on FINRA's website (via https://www
• Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials
• File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities
• Contact Theresa Reynolds (646-315-8567 or email) for questions
• Update internal compliance calendars, training, and systems to integrate the schedule

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] federalregister.gov

What Changed

Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110 SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital ≥$250,000 (as of Dec 31, 2025) comply for fi

What You Need To Do

• Submit all filings electronically via FINRA Gateway by 11:59 p
• For 30-day extension
• Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
• Prepare for Interactive Data
• Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] ria-compliance-consultants.com
• [7] fairviewinvest.com
• [8] thinkadvisor.com

What Changed

Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS

What You Need To Do

• Implement electronic signature processes (e
• Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
• Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
• Direct questions to firm's Risk Monitoring Analyst

Key Dates

References

• [1] quadrantregulatory.com
• [2] finra.org
• [3] pkfod.com
• [4] finra.org
• [5] quadrantregulatory.com
• [6] finra.org
• [7] capmktsreg.org

What Changed

National options exchanges will close at 1:00 p.m. ET on November 28, 2025, triggering a modified exercise cut-off under FINRA Rule 2360(b)(23)(A)(viii): deadline is 1 hour 30 minutes after close (i.e., 2:30 p.m. ET), overriding the standard 5:30 p.m. ET. Firms may set earlier internal deadlines for accepting exercise instructions but cannot accept any after 2:30 p.m. ET per FINRA Rule 2360(b)(23)(A)(vi). Reiterates standard procedures: in-the-money options auto-exercise under OCC Rule 805 (Exer

What You Need To Do

• Update client communications
• Configure systems and procedures
• Train staff
• Monitor and record
• Contact FINRA contacts (James Turnbull or Matthew Vitek) for clarification

Key Dates

References

• [1] finra.org
• [2] davispolk.com
• [3] finra.org
• [4] gtlaw.com
• [5] mayerbrown.com
• [6] finra.org
• [7] sec.gov
• [8] carltonfields.com

What Changed

The enforcement actions establish precedent in three critical areas: *Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans** and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition. *Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requ

What You Need To Do

• *For Registered Futures Firms and Banks
• trade and post-trade compliance controls
• *For Commodity Pool Operators and Investment Advisors:
• by-jurisdiction licensing analyses before soliciting investors
• *For All Market Participants

Key Dates

References

• [1] cftc.gov
• [2] jdsupra.com
• [3] cftc.gov
• [4] foley.com
• [5] lowenstein.com
• [6] cftc.gov
• [7] cohenco.com
• [8] cftc.gov

What Changed

The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.

What You Need To Do

• Verify registration with the CFTC at NFA BASIC before committing funds
• Review and update anti-spoofing and anti-fraud policies and procedures
• Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation

Key Dates

Related Regulations

What Changed

This announcement reflects structural reforms rather than new substantive regulations: Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy Directors. Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations. Complements parallel Wells process reforms under Chairman Paul Atkins, includin

What You Need To Do

• Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions
• Train legal/compliance staff on refined Wells process (e
• Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities
• Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions

Key Dates

References

• [1] jdsupra.com
• [2] dlapiper.com
• [3] mwe.com
• [4] corpgov.law.harvard.edu
• [5] foley.com
• [6] skadden.com
• [7] sec.gov
• [8] capx.cooley.com

What Changed

Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates. Increase the net asset threshold for investment companies from $50 million to $10 billion. Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification. Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulema

What You Need To Do

• Submit public comments by the deadline to influence thresholds, alternatives (e
• Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www
• Assess internal status
• No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules

Key Dates

References

• [1] sewkis.com
• [2] regulatoryandcompliance.com
• [3] jdsupra.com
• [4] sec.gov
• [5] freewritings.law
• [6] sec.gov
• [7] questce.com
• [8] sullivanlaw.com

What Changed

There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications. #

What You Need To Do

• related delays and monitor for successor announcements via https://www

Key Dates

References

• [1] sifma.org
• [2] sec.gov
• [3] securitiesdocket.com
• [4] sec.gov
• [5] ali.org
• [6] jonesday.com

What Changed

The final rule introduces the following substantive amendments: *Exceptions for Swaps Intended to be Cleared (ITBC Swaps)** Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution. Such swaps are deemed void if rejected from clearing. *Prime Broker Arrangement Exemptions** Swaps executed purs

What You Need To Do

• *Immediate Actions (Pre-Implementation)
• *Implementation Actions (Upon Effective Date)
• trade disclosure systems to remove PTMMM generation and delivery requirements
• based operations, review implications of superseded Staff Letter No
• *Ongoing Compliance

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] isda.org
• [4] gibsondunn.com
• [5] sifma.org
• [6] skadden.com

What Changed

This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reinforces longstanding CEA and CFTC rules on: Mandatory registration as a Commodity Pool Operator (CPO) and Associated Persons (APs) for pools trading commodity futures (CFTC Regulation 4.13 exemptions do not apply here due to fraud and public solicitation). Prohibitions on fraud, misrepresentations, guarantees of profit, non-disclosure of risks, commingling funds, and operating pools as

What You Need To Do

• Verify registration
• Implement controls
• Conduct due diligence
• Train staff
• For SEC-registered advisers

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] sidley.com
• [4] ropesgray.com
• [5] cftc.gov
• [6] haynesboone.com
• [7] cftc.gov
• [8] alston.com

What Changed

This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reaffirms existing CEA prohibitions on fraud, including Section 6(c)(1), 7 U.S.C. § 9(1), and 17 C.F.R. § 180.1(a)(1)-(3), covering material misrepresentations, omissions, and deceptive schemes in precious metals sales. Key takeaways include joint-and-several liability for entities and controlling individuals (Ikahn held liable for not acting in good faith), systematic overcharges as fraud

What You Need To Do

• Conduct immediate fraud risk assessments on precious metals sales scripts, disclosures, and pricing markups to ensure no material misrepresentations or undisclosed overcharges
• Enhance senior investor protections, including suitability reviews, cooling-off periods, and training on vulnerable customer targeting bans
• Review controlling person policies for good faith oversight, documenting supervisory failures to avoid personal liability
• Audit parallel SEC/CFTC exposures in commodity-linked activities, preparing for offset calculations in multi-agency actions
• Update compliance manuals with this case as precedent for CEA fraud in physical commodities; monitor whistleblower notices for internal reporting incentives

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] whistleblower.gov
• [4] oag.maryland.gov
• [5] nasaa.org
• [6] cftc.gov
• [7] securities.utah.gov
• [8] finance.idaho.gov

What Changed

This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including: Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program. Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, no

What You Need To Do

• Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities
• Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes
• Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories
• Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast

Key Dates

References

• [1] mcguirewoods.com
• [2] sec.gov
• [3] dechert.com
• [4] corpgov.law.harvard.edu
• [5] skadden.com
• [6] perkinscoie.com
• [7] morganlewis.com
• [8] clearygottlieb.com

What Changed

This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements introduced. It reaffirms existing prohibitions under CEA Section 6(c)(2) against wash sales (fictitious sales) and non-competitive transactions that negate risk or price competition in futures markets. The case highlights CFTC's interpretation of wash sales as including trades where buy and sell orders for identical quantities of the same contract are executed near-simultaneously for accounts

What You Need To Do

• Enhance trade surveillance
• Conduct gap analysis
• Strengthen internal controls
• Self-reporting consideration
• Training and recordkeeping

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] mayerbrown.com
• [4] phoenixstrategy.group
• [5] paulhastings.com
• [6] cftc.gov
• [7] figment.io
• [8] coincenter.org