No description available.
Broker DealerBank
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Broker Dealer
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Broker DealerAll Firms
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The CFTC has issued a Notice of Proposed Rulemaking (NPRM) to amend Part 37 (SEFs), Part 38 (DCMs), Part 39 (DCOs), and regulations 1.52 and 1.55 to address **affiliations and vertically integrated structures** among CFTC‑regulated entities and market participants. The proposal is explicitly aimed at managing **actual and perceived conflicts of interest** in affiliated structures (e.g. exchange/clearinghouse/intermediary/market‑maker combinations) through principles‑based rules that preserve responsible innovation while reinforcing market integrity.
What Changed
- - Introduces principles‑based requirements for vertically integrated market structures involving affiliations between derivatives clearing organizations, designated contract markets, swap execution...
- Amends Part 37 to set additional governance, conflict‑management, and structural requirements for swap execution facilities where the SEF is affiliated with an intermediary or trading entity.
- Amends Part 38 to impose enhanced conflict‑of‑interest and self‑regulatory safeguards for designated contract markets that are affiliated with futures commission merchants or proprietary trading...
- Amends Part 39 to clarify and strengthen requirements on derivatives clearing organizations in group structures where the DCO is affiliated with intermediaries or other market participants, including...
- Amends regulation 1.52 (accounts and records; FCM supervisory requirements) to reflect the heightened expectations placed on futures commission merchants that are part of vertically integrated...
Suggested Considerations
- Identify and map all affiliate relationships involving CFTC‑regulated entities within your group (DCO, DCM, SEF, FCM, SD/MSP, trading entities, market makers) and document how roles and control relationships could create actual or perceived conflicts of interest.
- Conduct a gap analysis of existing governance, conflicts‑of‑interest, information‑barrier, and supervision frameworks against the anticipated principles‑based expectations for vertically integrated structures under Parts 37, 38, 39 and regulations 1.52 and 1.55.
- Review and, where necessary, enhance board‑level and committee‑level oversight arrangements for affiliated entities to ensure independent decision‑making on listing, clearing, rule enforcement, membership, and client treatment where affiliates are involved.
- Assess current customer risk disclosures, including those required under regulation 1.55 for FCMs, to determine whether affiliate relationships and related conflicts are adequately described, and prepare draft revisions that could be implemented if the new requirements are finalized.
- Engage legal, compliance, and business stakeholders for each affected entity (DCO, DCM, SEF, FCM, trading entity) to prepare a coordinated comment letter to the CFTC explaining operational impacts, potential unintended consequences, and recommendations on specific rule language.
Key Dates
- Potential adoption of final rules on affiliations requirements, depending on the volume and content of comments and Commission deliberations
- Federal Register publication date of the NPRM on affiliations (the comment deadline will run for 60 days from this publication; firms should monitor the Federal Register and CFTC website to confirm the exact date)
- CFTC issues press release announcing the Notice of Proposed Rulemaking on affiliations among CFTC‑regulated entities and indicates that comments will be accepted for 60 days following publication in the Federal Register
- End of public comment period on the proposed amendments to Parts 37, 38, 39 and regulations 1.52 and 1.55 concerning affiliations and vertically integrated market structures
Compliance Impact
Non‑compliance with the eventual affiliation rules is likely to be treated as a significant governance and market‑integrity issue, potentially affecting registration, examinations, enforcement exposure, and the viability of vertically integrated business models. Firms with complex group structures should treat this as a high‑impact regulatory development, with particular consequences for exchanges, clearinghouses, SEFs, and FCMs that rely on affiliated market‑making or intermediation.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager The Securities and Exchange Commission announced that the Small Business Capital Formation Advisory Committee meeting held on July 21, 2026, will reconvene August 6, 2026, at 1 p.m. ET, virtually, on SEC.gov. The committee will…
All Firms
No description available.
Broker DealerBankAll Firms
The Securities and Exchange Commission released a report to Congress today highlighting policy recommendations from the SEC’s 45th Annual Government-Business Forum on Small Business Capital Formation. The report provides a summary of the forum…
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Broker Dealer
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Crypto Exchange
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The CFTC has extended by 30 days the public comment period on its targeted Request for Comment (RFC) covering (i) extension of **standard futures contracts (including energy futures) to 24/7 trading** and (ii) **perpetual contracts referencing physically delivered or storable energy commodities**. This extension signals that the Commission intends to build a more complete record on market structure, risk management, and investor protection before setting a regulatory framework, and compliance teams in energy and derivatives markets now have additional time to shape that framework and align their controls with emerging expectations.
What Changed
- - The CFTC has extended the comment deadline on the RFC regarding 24/7 trading of standard futures contracts and perpetual contracts in energy markets by 30 days, moving the due date to 26 August...
- The RFC focuses on the extension of standard futures contracts, including energy futures, to a 24/7 trading schedule while keeping fixed expirations but allowing potentially material economic changes...
- The RFC separately focuses on the listing and regulation of perpetual contracts that reference physically delivered or storable energy commodities, such as crude oil, and that have no fixed...
- The Commission has added additional questions to the original RFC to probe market integrity, price formation, operational resilience, customer protections, and risk management implications of 24/7...
- The RFC builds on and is informed by the CFTC’s May 29, 2026 coordinated actions on perpetual contracts and 24/7 trading in digital commodities, including the Policy Statement on perpetual contracts,...
Suggested Considerations
- Identify and convene an internal cross‑functional working group (trading, risk, operations, compliance, legal, and IT) to assess potential impacts of 24/7 trading and energy perpetual contracts on your firm’s business model and control environment.
- Perform a gap analysis of current trading, clearing, surveillance, margin, and risk management frameworks against the operational and risk expectations articulated in recent CFTC staff advisories and policy statements on 24/7 markets and perpetual contracts.
- Draft and submit a data‑driven comment to the CFTC by 26 August 2026 addressing the RFC questions most relevant to your activities, including empirical analysis of liquidity, price formation, manipulation risk, funding rate behavior, and customer protection in energy derivatives.
- Review and update internal policies and procedures for trade surveillance, market abuse monitoring, and manipulation detection to address continuous 24/7 trading windows and any contemplated use of energy perpetual contracts.
- Assess whether current staffing models, systems support, and incident‑response processes can support 24/7 trading or clearing operations, and document enhancements or mitigations that would be needed to maintain operational resilience.
Key Dates
- CFTC issues the targeted request for comment on extending standard energy futures to 24/7 trading and on the listing of perpetual contracts referencing physically delivered or storable energy commodities
- Original 30‑day comment deadline for the RFC on 24/7 trading and energy perpetual contracts (now superseded by the extension)
- Extended deadline for submission of public comments on the RFC regarding 24/7 trading of standard energy futures and perpetual contracts referencing physically delivered or storable energy commodities
Compliance Impact
Non‑compliance with eventual CFTC expectations and rules around 24/7 trading and perpetual energy contracts could result in denial of product listings, enforcement action for inadequate risk controls or misleading disclosures, and heightened supervisory scrutiny. Early alignment with the RFC themes and proactive engagement with the CFTC will reduce regulatory risk and position firms favorably as the framework solidifies.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerHedge FundCrypto Exchange No description available.
Broker DealerAll Firms
The Securities and Exchange Commission announced today that it will host a roundtable on Sept. 17, 2026, to discuss moving towards 24-hour trading in the U.S. equity markets, including preparations to support overnight trading, operations and resiliency…
Broker DealerAll Firms
The Securities and Exchange Commission today announced that Sam Waldon, Principal Deputy Director of the Division of Enforcement, will depart the agency on July 31, 2026, after more than 14 years at the SEC. He will be succeeded as Principal Deputy…
The SEC has announced that **Principal Deputy Director of Enforcement Sam Waldon will depart the agency on 31 July 2026**, and that he will be succeeded as Principal Deputy Director by another senior Enforcement Division leader (name specified in the release). This leadership change matters for compliance teams because Waldon has been a central architect of recent Enforcement Division restructuring, prioritization of “core” fraud cases, and changes to investigative and Wells processes; his departure and successor may recalibrate enforcement focus, case selection, and expectations around cooperation and remediation.
What Changed
- - The SEC has formally announced that Principal Deputy Director of the Division of Enforcement Sam Waldon will leave the agency effective 31 July 2026, ending more than 14 years of service at the SEC.
- The Enforcement Division will have a new Principal Deputy Director (named in the release), who will assume responsibility for overseeing day‑to‑day enforcement operations, supervision of regional and...
- Waldon’s departure follows his recent tenure as Acting Director and Principal Deputy Director during a period of strategic restructuring of the Enforcement Division, including creation of multiple...
- The transition occurs against the backdrop of earlier Commission decisions to rescind delegation of formal order authority to the Enforcement Director, returning formal order approvals to the...
- Under Waldon’s leadership, the Division emphasized “quality over quantity” cases, focusing on traditional “core” areas (insider trading, accounting and disclosure fraud, market manipulation,...
Suggested Considerations
- Review and update enforcement‑risk assessments to reflect the forthcoming change in SEC Enforcement Division Principal Deputy Director, with particular focus on core fraud, insider trading, and accounting‑related risks.
- Re‑evaluate internal investigation, Wells process, and SEC engagement protocols to ensure they align with current Enforcement Manual practices and anticipate any refinements under the new Principal Deputy Director.
- Brief senior management, boards, and audit committees on the SEC enforcement leadership transition and its implications for prioritization of accounting, disclosure, and gatekeeper cases, particularly in light of the SOX‑focused enforcement unit.
- Reassess crypto and digital asset exposure, including ongoing or threatened SEC matters, to account for potential shifts in enforcement posture under new leadership while maintaining preparedness for fraud‑focused actions involving retail investors.
- Reinforce insider trading surveillance, market‑abuse monitoring, and controls around material non‑public information, reflecting the Enforcement Division’s continued emphasis on traditional trading‑related misconduct.
Key Dates
- Judge Margaret A. Ryan’s resignation as Director of the Division of Enforcement becomes effective, and Principal Deputy Director Sam Waldon is named Acting Director of Enforcement
- David Woodcock is named permanent Director of the Division of Enforcement, succeeding Judge Ryan
- Principal Deputy Director of Enforcement Sam Waldon departs the SEC after more than 14 years at the agency; his successor assumes the role of Principal Deputy Director
Compliance Impact
Non‑compliance with securities‑law obligations in core enforcement areas (fraud, insider trading, accounting and disclosure violations, market manipulation, and fiduciary breaches) remains subject to significant SEC sanctions, including civil penalties, disgorgement, bars, and undertakings. The leadership transition does not lessen enforcement risk; instead, it may refine focus and increase predictability around investor‑harm cases, making robust controls and documented remediation essential to mitigate potential penalties and collateral consequences.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAsset ManagerBank No description available.
Broker DealerBank
The Securities and Exchange Commission today proposed Regulation E-Delivery, a new rule that would expand the ability of issuers, broker-dealers, investment advisers, and others to use electronic delivery to satisfy information delivery requirements…
The SEC has proposed **Regulation E‑Delivery**, a new, technology‑neutral rule that would allow electronic delivery to become the **default method** for satisfying many information delivery requirements under the federal securities laws, while preserving a right to paper on request. This is a material shift away from the long‑standing, guidance‑based and “affirmative consent” model, and will require firms to redesign their disclosure, investor communication and recordkeeping frameworks to comply with new notice, opt‑out and failure‑remediation obligations.
What Changed
- - Regulation E‑Delivery would formally replace the SEC’s decades‑old, purely guidance‑based approach to electronic delivery and establish a rule‑based framework that expressly permits e‑delivery to...
- Electronic delivery would become the default method of delivery, meaning firms could deliver required regulatory information electronically without first obtaining the investor’s affirmative consent,...
- The rule would preserve investor choice by requiring that investors and other recipients be able to request paper delivery at any time and continue receiving paper format upon request.
- The proposal would set out requirements and conditions for when e‑delivery is deemed compliant, including use of electronic addresses or other electronic methods reasonably designed to ensure receipt...
- The range of deliverable documents under Regulation E‑Delivery would be broad, covering prospectuses for funds and other issuers, fund annual and semi‑annual shareholder reports, proxy statements,...
Suggested Considerations
- Conduct a comprehensive mapping of all documents currently delivered under federal securities law requirements (prospectuses, shareholder reports, proxy materials, trade confirmations, Form CRS, Form ADV brochures) and determine how each will be delivered under Regulation E‑Delivery.
- Review and update disclosure, investor communication and delivery policies to incorporate e‑delivery as the default method while clearly documenting investor rights to request and receive paper delivery at any time.
- Design and implement procedures for maintaining accurate electronic contact information for investors and clients, including periodic verification processes and remediation steps for undeliverable emails or failed electronic transmissions.
- Develop and operationalize the transition process for paper‑based recipients, including generation and mailing of the two required paper notices that explain the move to e‑delivery and the opt‑out option.
- Update client and investor onboarding materials, account agreements and preference‑capture workflows to reflect the new default e‑delivery model and how investors can elect paper delivery or change their preferences.
Key Dates
– Start of the 60‑day public comment period on the Regulation E‑Delivery proposal
– End of the 60‑day comment period; market participants must have submitted feedback on scope, conditions, investor protections and operational impacts by this date
– Effective date of final Regulation E‑Delivery, after which firms may begin relying on the rule for default e‑delivery, subject to any specified compliance or phase‑in dates in the adopting release
– Commencement of required transition processes, including the mailing of two paper notices and implementation of opt‑out mechanisms, for investors currently receiving paper communications
Compliance Impact
Non‑compliance could result in failures to meet statutory disclosure and delivery obligations, exposing firms to SEC enforcement, supervisory findings, investor complaints, and potential civil liability where investors allege inadequate or inaccessible information. Mismanaged transitions or poor controls around e‑delivery failures may also create conduct risk, reputational damage and remediation costs, particularly for retail and senior investors.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerWealth Manager No description available.
Broker DealerAll Firms
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Broker DealerCrypto Exchange
No description available.
Asset ManagerBroker DealerHedge Fund The Securities and Exchange Commission’s Office of Municipal Securities today announced it has updated its Registration of Municipal Advisors FAQs webpage to offer more clarity on municipal advisor registration and recordkeeping requirements. The…
The SEC Office of Municipal Securities has updated its **Registration of Municipal Advisors FAQs** to clarify when public‑private partnership (P3) participants must register as municipal advisors, how Form MA/MA‑I filers must treat **remote work locations as “offices”**, and the **recordkeeping scope** when advising on pricing of new municipal issues. The FAQs also add explicit guidance on **how to register** (including for sole proprietors) and cross‑reference existing SEC staff and MSRB resources, effectively tightening expectations around registration and books-and-records controls for municipal advisory activity.
What Changed
- - The FAQs now provide targeted guidance for public‑private partnership (P3) market participants on when their activities in structuring or advising on P3 financings constitute municipal advisory...
- The FAQs clarify for Form MA and Form MA‑I filers which remote work locations where municipal advisor‑related business is conducted must be disclosed as an “office,” affecting how firms classify and...
- The FAQs add staff views on the scope of recordkeeping requirements when a municipal advisor provides advice on the pricing of a new issue of municipal securities, reinforcing obligations under...
- A new FAQ explains how to register as a municipal advisor, directing prospective advisors (including sole proprietors) to an existing SEC staff Informational Bulletin and MSRB compliance resource...
- The SEC reiterates that the final municipal advisor registration rules adopted in 2013 remain in force and emphasizes that firms and individuals conducting municipal advisory activity should “come...
Suggested Considerations
- Conduct a comprehensive assessment of public‑private partnership activities to determine whether any structuring, advisory, or financing work for state or local governments involves “municipal advisory activities” that trigger SEC municipal advisor registration requirements.
- Review all current and planned municipal advisory activities (including indirect advice through third‑party professionals) against the SEC’s municipal advisor definition, exclusions, and exemptions, and document registration determinations in a formal internal memo.
- Identify all locations, including employees’ remote and home offices, where municipal advisor‑related business is conducted, and update Form MA and Form MA‑I filings to ensure accurate disclosure of “offices” according to the new FAQ guidance.
- Review and, where necessary, update books‑and‑records policies and procedures to ensure that advice on pricing of new issues of municipal securities is fully captured, including communications, analyses, models, and recommendations, in line with SEC and MSRB recordkeeping standards.
- Establish or update onboarding and change‑management controls to ensure that new municipal advisory lines of business, new P3 mandates, or expansions into remote work arrangements are reviewed by compliance for municipal advisor registration and office‑reporting implications before launch.
Key Dates
- SEC Office of Municipal Securities updates the Registration of Municipal Advisors FAQs to add guidance on completion and timelines for Form MA, Form MA‑I, and Form MA‑NR, setting baseline expectations for registration filings and updates
- SEC updates the Registration of Municipal Advisors FAQs to provide additional staff views for public finance market participants on when their activities require municipal advisor registration
- SEC Office of Municipal Securities issues the latest update to the Registration of Municipal Advisors FAQs, adding clarifications for P3 participants, remote work office disclosures on Forms MA/MA‑I, recordkeeping scope for pricing advice, and a new FAQ on how to register as a municipal advisor
Compliance Impact
Non‑compliance primarily risks unregistered municipal advisory activity and deficient recordkeeping, which can lead to SEC enforcement actions, censures, monetary penalties, and potential restrictions on municipal advisory business. The clarification around remote offices also increases the likelihood of registration form deficiencies being identified through exams or surveillance.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAsset ManagerBank No description available.
Broker Dealer
The Securities and Exchange Commission’s Office of the Advocate for Small Business Capital Formation and the Division of Corporation Finance will co-host a livestreamed discussion on Monday, July 13, 2026, at 2 p.m. to re-examine…
Broker DealerAsset Manager
The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee announced that it will hold a meeting on Tuesday, July 21, 2026 at 10 a.m. to explore ways to modernize public market access and encourage IPOs…
Broker DealerAll Firms
No description available.
Asset ManagerHedge Fund
The Securities and Exchange Commission today announced the creation of the Retail Fraud Working Group designed to strengthen the Division of Enforcement’s efforts to identify and combat fraud targeting everyday investors.The Retail Fraud Working Group…
What Changed
- - The SEC is reinstating the Retail Fraud Working Group within the Division of Enforcement to concentrate resources on identifying and pursuing misconduct that disproportionately harms retail...
- The Working Group will support stronger coordination with state and federal enforcement partners, including improved information-sharing and joint efforts.
- The SEC’s enforcement priorities now explicitly include offering fraud, accounting and disclosure fraud, insider trading, market manipulation, fraud by foreign actors, and fiduciary breaches...
- The SEC is signaling that it will distinguish between honest mistakes and actual fraud, but will still assess whether errors caused investor harm and calibrate remedies accordingly.
- The initiative reinforces the SEC’s broader retail-investor focus, building on the earlier Retail Strategy Task Force and related retail-protection efforts.
Suggested Considerations
- Review retail-facing sales, disclosure, and supervision controls for gaps that could create exposure under SEC fraud theories.
- Reassess product approval, marketing review, and suitability procedures for offerings sold to individual investors.
- Test whether financial reporting, performance, and valuation disclosures could be challenged as misleading or incomplete.
- Strengthen surveillance for insider trading, market manipulation, and suspicious transaction patterns involving retail accounts.
- Reevaluate client-asset safeguarding, custody, and trade-allocation controls to prevent misuse or misappropriation.
Key Dates
- The Retail Fraud Working Group begins operating as an internal enforcement priority; the announcement does not specify a formal launch date or implementation timetable
- SEC Enforcement Director David Woodcock publicly stated that the Retail Fraud Working Group would be reinstituted and that it would focus on protecting retail investors and strengthening coordination with state and federal partners
Compliance Impact
The compliance impact is high because the SEC is signaling more targeted examinations and enforcement cases involving conduct that affects retail investors. Firms that fail to identify retail harm, disclose conflicts, or protect client assets face increased risk of investigations, injunctions, penalties, undertakings, and reputational damage.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerWealth Manager The Securities and Exchange Commission today announced that Paul Knight has been named as the agency’s Chief Operating Officer (COO).As COO, Mr. Knight will oversee the SEC's operational and administrative functions, including the agency's Office of…
All Firms
No description available.
Crypto ExchangeBroker DealerAll Firms
The Securities and Exchange Commission’s Division of Economic and Risk Analysis (DERA) published updated statistics and data visualizations covering key segments of the U.S. capital markets, including three new asset-backed securities (ABS) issuance data…
Broker DealerAll Firms
The Securities and Exchange Commission today issued a request for public comment on exchange-traded funds (ETFs) seeking to invest in innovative asset classes or engage in novel investment strategies. The request focuses on ways to facilitate innovation…
Asset ManagerBroker Dealer
No description available.
Broker DealerFintech
No description available.
Broker DealerAsset ManagerHedge Fund
The Securities and Exchange Commission and the Commodity Futures Trading Commission today issued a joint request for public comment on potential approaches to further harmonize regulatory frameworks applicable to portfolio margining across securities,…
Broker DealerAsset ManagerHedge Fund
No description available.
The CFTC has proposed amendments to Parts 15, 16, and 17 to establish a new reporting regime for certain covered event contracts, including a new **§16.03 “Covered Event Contracts”** provision. If adopted, the rule would require relevant market participants to report these contracts under the Parts 15 through 18 framework rather than under selected reporting provisions in Parts 38, 39, 43, and 45, making this a material compliance redesign for firms active in event contracts.
What Changed
- - The CFTC proposes an alternate reporting framework for certain fully collateralized event contracts, replacing reliance on certain reporting provisions in Parts 38, 39, 43, and 45 with reporting...
- The proposal would amend Part 15, Part 16, and Part 17 of the CFTC’s regulations.
- The proposal would add a new §16.03 titled “Covered Event Contracts” to Part 16.
- The proposal would require reporting pursuant to §16.00, §16.01, Part 17, and Part 18 for covered event contracts.
- The proposal would apply to reporting by certain reporting markets, futures commission merchants, clearing members, and foreign brokers.
Suggested Considerations
- Firms that list, clear, intermediate, or report covered event contracts should inventory all event-contract products and map each product to the current reporting regime and the proposed Parts 15 through 18 framework.
- Compliance teams should identify all reporting fields, systems, and workflows currently relying on Parts 38, 39, 43, or 45 for event-contract reporting and assess whether those processes would need redesign.
- FCMs, clearing members, and foreign brokers should review their data governance and source-of-truth controls to ensure they can produce the reporting elements required under §16.00, §16.01, Part 17, and Part 18 if the proposal is adopted.
- Firms should track the public-comment process and prepare comments if the proposed framework creates operational gaps, duplicated reporting, or ambiguities in product scope.
- Market participants should review reliance on existing no-action letters and prepare contingency plans for a transition from interim relief to a codified rule.
Key Dates
- Staff no-action letters began providing the interim reporting approach for certain fully collateralized event contracts
- The proposal will proceed through the public-comment process and could later be finalized, subject to Commission action
- CFTC staff issued a no-action letter regarding swap data reporting and recordkeeping for event contracts, reinforcing the temporary relief framework
- The CFTC published the Notice of Proposed Rulemaking seeking public comment on amendments to Parts 15, 16, and 17
Compliance Impact
The compliance impact is moderate to high because the proposal could require firms to re-engineer reporting architecture, amend procedures, and retest controls for event-contract data submission. Non-compliance after final adoption could expose firms to CFTC supervisory findings, reporting deficiencies, and possible enforcement risk if required data are not reported correctly or on time.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerBankAll Firms
The Securities and Exchange Commission has appointed Kathleen M. Hutchinson as Director of the agency’s Office of International Affairs (OIA). OIA advises the Commission on international policy matters, coordinates with foreign authorities across the…
All Firms
No description available.
The CFTC has filed a federal lawsuit against the Commonwealth of Kentucky (23 June 2026) to stop the state from using gambling‑style enforcement actions and a special transaction fee to effectively shut down CFTC‑registered designated contract markets (DCMs), including prediction markets. The case is a direct assertion of the CFTC’s *exclusive federal jurisdiction* over futures, options, and swaps, and it materially raises the compliance stakes for any CFTC‑registered market, intermediary, or participant operating in or targeted by state gambling or consumer‑protection regimes.
What Changed
- - The CFTC has initiated federal litigation against Kentucky seeking declaratory and injunctive relief to prevent the state from enforcing civil actions and special transaction fees against...
- Kentucky has filed civil enforcement actions in state court against CFTC‑regulated DCMs, characterising their event contracts as illegal gambling and seeking substantial monetary penalties.
- Kentucky has adopted a new “special transaction fee” (functionally an excise or levy) specifically targeting transactions on CFTC‑regulated DCMs, intended to incentivise these platforms to cease...
- The CFTC is explicitly framing Kentucky’s actions as an impermissible interference with Congress’s federal preemption framework and the CFTC’s exclusive jurisdiction over futures, options, and swaps,...
- The Commission is building a broader litigation strategy, noting parallel proceedings against Minnesota, Illinois, and Rhode Island and amicus participation before the Sixth and Ninth Circuits and...
Suggested Considerations
- Review and update state‑law risk assessments for all CFTC‑regulated DCM activities, with a specific focus on gambling, consumer‑protection, tax, and licensing regimes in Kentucky and other active states.
- Conduct a targeted legal analysis of whether existing or planned event‑based or prediction‑market contracts might be recharacterised as gambling under relevant state laws, and document the basis for treating them as CFTC‑regulated derivatives.
- Map all customer‑facing operations, servers, marketing, and on‑the‑ground presence in Kentucky and other contentious states, and evaluate whether operational changes (e.g. geofencing, revised onboarding flows) are warranted pending judicial outcomes.
- Engage external counsel to monitor *CFTC v. Kentucky* and related state and federal cases, and establish an internal escalation protocol so that material developments (e.g. injunctions, adverse rulings) trigger prompt compliance and product‑governance review.
- Update board and senior management reporting to include a standing item on state–federal jurisdictional conflicts affecting prediction markets, highlighting litigation exposure, revenue at risk, and contingency plans.
Key Dates
- CFTC files its lawsuit against Kentucky to block enforcement actions and special transaction fees against CFTC‑registered DCMs
- Key procedural milestones in *CFTC v. Kentucky* (motion practice, preliminary injunction hearings, and potential appellate review), which will shape how quickly and broadly federal preemption over prediction markets is clarified
- Progression of related CFTC suits and amicus‑briefed appeals in the Sixth Circuit, Ninth Circuit, and Massachusetts Supreme Judicial Court, which will collectively define the jurisdictional perimeter for event contracts
Compliance Impact
Non‑compliance, or mismanagement of overlapping state and federal regimes, can result in significant state‑level monetary penalties, special fees, potential orders to cease operations, and parallel federal enforcement or supervisory actions. The litigation also increases reputational and regulatory‑relationship risk for firms seen as disregarding the emerging federal–state boundary around prediction markets.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerHedge FundCrypto Exchange No description available.
Broker DealerAll Firms
No description available.
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No description available.
Broker DealerAsset ManagerAll Firms
No description available.
Broker DealerAsset Manager
The Securities and Exchange Commission and the Commodity Futures Trading Commission today issued a joint request for public comment on potential opportunities to further update, clarify, and harmonize certain derivatives product definitions and…
Broker DealerAsset ManagerAll Firms
No description available.
Crypto ExchangeFintech
The Securities and Exchange Commission and Commodity Futures Trading Commission today issued a joint request for public comment on potential opportunities to harmonize, modernize, and streamline data reporting requirements in their regulation of the…
Broker DealerBankAll Firms
No description available.
Broker DealerAll Firms
No description available.
FintechBroker DealerBank
No description available.
All Firms
No description available.
Broker Dealer
The Securities and Exchange Commission has appointed John Moses as Director of the agency’s Office of Investor Education and Assistance, which provides services and resources to help investors build their financial futures and protect against investment…
All Firms
No description available.
Broker DealerCrypto Exchange
The Securities and Exchange Commission today proposed amendments to rescind Rules 611 and 610(e) of Regulation NMS.“After two decades of Rule 611, it is high time that the Commission review its unintended consequences that have hindered — rather than…
The SEC has proposed to **rescind Regulation NMS Rules 611 (Order Protection Rule) and 610(e) (quotations access fee cap)**, fundamentally re‑opening how U.S. equity markets handle trade‑through protection and access fee limits. For compliance teams at equity trading venues and intermediaries, this is a structural market‑microstructure change that will eventually require re‑engineering best‑execution, routing, and surveillance frameworks that are currently built around Rule 611’s trade‑through regime and Rule 610(e)’s fee cap.
What Changed
- - The SEC proposes to rescind Rule 611 of Regulation NMS (17 CFR 242.611), which currently requires trading centers to establish, maintain, and enforce written policies and procedures reasonably...
- The rescission would eliminate the current requirement on trading centers to prevent executions at prices inferior to protected quotations displayed on other trading centers, subject to the present...
- The SEC proposes to rescind Rule 610(e) of Regulation NMS, which currently imposes caps on access fees that trading centers may charge for the execution of quotations in NMS stocks, intended to...
- The proposal would remove the regulatory framework that links protection of top‑of‑book quotations with capped access fees, allowing market forces and competition to shape routing behavior, fee...
- The proposal would likely be accompanied by conforming amendments to related definitions and cross‑references in Regulation NMS that currently rely on or reference Rules 611 and 610(e).
Suggested Considerations
- Map all current policies, procedures, and controls that explicitly reference or rely on Rule 611 (Order Protection Rule) and Rule 610(e) (access fee caps), including best‑execution frameworks, routing policies, fee schedules, and surveillance rules.
- Conduct a system inventory of smart order routing, execution algorithms, and venue connectivity logic that prevents trade‑throughs of protected quotations and enforces access‑fee caps, and identify components that would need redesign if Rules 611 and 610(e) are rescinded.
- Review and, if necessary, update best‑execution policies and client disclosures to decouple best‑execution rationales from mechanical Rule 611 compliance, preparing a framework that can operate in an environment without trade‑through prohibitions or fee caps.
- Enhance governance processes to monitor the SEC rulemaking, assign ownership (e.g., to a market structure working group), and prepare internal impact assessments and board‑level briefings on potential business, conduct, and conflict‑of‑interest implications of rescission.
- Develop scenario analyses and playbooks describing how routing strategies, venue selection, and payment‑for‑order‑flow or other economic arrangements would be adjusted in the absence of Rule 611 and Rule 610(e).
Key Dates
– Potential SEC adoption of a final rule rescinding Rules 611 and 610(e), including any specified effective and compliance dates
– SEC proposal to rescind Regulation NMS Rules 611 and 610(e) is published, starting the public comment period
– End of the initial public comment period on the proposal to rescind Rules 611 and 610(e)
Compliance Impact
Rescission would not immediately apply until a final rule and effective date, but once effective it will require a fundamental re‑design of U.S. equity order‑routing, best‑execution, and surveillance frameworks that have been built around Regulation NMS’s order‑protection architecture. Non‑compliance with any new framework (and with ongoing best‑execution and conduct duties during and after the transition) could lead to enforcement actions, client disputes, and significant market conduct risk, even if the specific NMS provisions are removed.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager No description available.
The CFTC is proposing to revise its whistleblower award framework to make smaller awards more predictable by presuming a **30% award rate for claims of $5 million or less**, subject to Commission judgment. This is a significant compliance development because it aligns more closely with SEC whistleblower methodology and may encourage more whistleblower submissions tied to Commodity Exchange Act violations, increasing the need for firms to detect issues early and respond quickly.
What Changed
- - The CFTC proposes a 30% presumption for whistleblower awards of $5 million or less.
- The presumption remains subject to Commission discretion and application of relevant regulatory factors.
- The proposal is modeled on SEC Rule 21F-6(c) to further harmonize CFTC and SEC whistleblower frameworks.
- The CFTC says the change is intended to improve the efficiency, transparency, and predictability of award processing.
- The proposal would affect how the CFTC’s Whistleblower Office evaluates award claims under Part 165.
Suggested Considerations
- Review whistleblower intake, escalation, and investigation procedures to ensure the firm can identify potential CEA violations before they become external whistleblower submissions.
- Update training for front office, operations, compliance, and management personnel on CFTC whistleblower protections and the increased incentive structure.
- Assess whether confidentiality, reporting, and non-retaliation controls are sufficiently documented to withstand scrutiny if a whistleblower complaint arises.
- Reconfirm that internal policies do not discourage employees from communicating with the CFTC or otherwise create retaliation risk.
- Monitor the Federal Register publication date and decide whether the firm, trade association, or counsel should submit a comment during the open comment period.
Key Dates
- The CFTC published the Notice of Proposed Rulemaking seeking public comment on amendments to its whistleblower rules
- The public comment period closes 30 days after the NPRM is published in the Federal Register
- The CFTC may finalize, modify, or withdraw the proposal after reviewing public comments
Compliance Impact
The practical impact is moderate to high because the proposal raises the attractiveness of reporting to the CFTC and may increase the likelihood of externally originated enforcement matters. Firms that fail to maintain strong internal reporting channels, prompt investigations, and anti-retaliation safeguards face higher risk of enforcement, litigation, and reputational harm if a whistleblower report is filed.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerAsset ManagerHedge Fund No description available.
Broker DealerCrypto ExchangeFintech
No description available.
The CFTC has issued a Notice of Proposed Rulemaking (NPRM) to amend Regulation 40.11 and add Appendix F to Part 40 to create a **structured, time‑bound framework** for reviewing event contracts that may involve the activities enumerated in CEA Section 5c(c)(5)(C) (terrorism, assassination, war, gaming, or unlawful conduct). This proposal matters because it will formalize how the CFTC determines whether such event contracts are **contrary to the public interest** and therefore cannot be listed or cleared by CFTC‑registered entities, with particular consequences for prediction markets and sports, political, and other “gaming” event contracts.
What Changed
- - The NPRM would amend CFTC Regulation 40.11 to embed a formal analytical framework for assessing whether an event contract involves an activity enumerated in CEA Section 5c(c)(5)(C) and, if so,...
- The NPRM would add Appendix F to Part 40 to set out the factors, tests, and procedural steps the Commission will apply when reviewing specific event contracts referencing enumerated activities.
- The proposal would define key statutory terms, including at minimum “involve” and “gaming,” to clarify when an event contract is considered to touch an enumerated activity under CEA Section...
- The NPRM would establish a 90‑day review process for the Commission to evaluate event contracts that may implicate enumerated activities, including procedural protections such as notice, opportunity...
- The proposed framework would codify public‑interest factors the Commission will apply when deciding whether a particular contract involving an enumerated activity is contrary to the public interest...
Suggested Considerations
- Map and inventory all existing and planned event contracts listed or cleared through CFTC‑registered entities to identify those that may “involve” terrorism, assassination, war, gaming, or conduct unlawful under federal or state law.
- Conduct a legal analysis of how the proposed definitions of “involve” and “gaming” would apply to your current product set, particularly sports, political, entertainment, and other contest‑based contracts, and document the rationale.
- Review and update internal product‑approval and new‑contract listing procedures to incorporate the proposed 90‑day CFTC review process, including timelines, documentation standards, and decision gates tied to Section 5c(c)(5)(C).
- Develop or update written policies and controls to ensure that contracts potentially involving enumerated activities are escalated for legal, compliance, and regulatory‑affairs review before submission to the CFTC.
- For DCMs and SEFs, enhance product‑submission templates to clearly address the proposed Appendix F public‑interest factors, including description of the underlying event, potential for unlawful activity, market integrity risks, and consumer‑protection considerations.
Key Dates
– Earlier CFTC NPRM on event contracts was published in the Federal Register as “Event Contracts; Proposed Rule, 89 FR 48968,” later withdrawn on 06 February 2026; the new NPRM effectively replaces that initiative with a more targeted framework
– CFTC formally withdrew the 2024 Event Contracts proposed regulatory action (91 FR 5386), clearing the path for the current, more targeted NPRM on enumerated activities
– CFTC issued an Advance Notice of Proposed Rulemaking (ANPRM) on prediction markets and a staff advisory to DCMs, launching a broader process to develop a tailored regulatory framework for prediction markets
– Comment deadline for the March 2026 prediction‑markets ANPRM, which this NPRM is described as addressing in part and which may lead to additional rulemaking
– CFTC announces the new NPRM on amendments to Regulation 40.11 and addition of Appendix F to Part 40 regarding event contracts involving enumerated activities
Compliance Impact
Non‑compliance with the final rules emerging from this NPRM could result in the CFTC determining that listed or cleared contracts are contrary to the public interest, leading to forced delisting, enforcement exposure, and reputational damage for CFTC‑registered entities. The impact is particularly significant for firms whose business models rely on sports, political, and other “gaming” event contracts, as entire product lines may become impermissible if they are found to involve enumerated activities in a way that is contrary to the public interest.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerFintechCrypto Exchange The U.S. Securities and Exchange Commission established joint data standards under the Financial Data Transparency Act of 2022. The final rule establishes technical standards for data submitted to certain financial regulatory agencies. Eight additional…
The SEC has adopted **joint data standards** under the Financial Data Transparency Act of 2022 (FDTA) to govern how data is formatted and submitted to specified U.S. financial regulators, including the SEC. This materially raises the bar on data structure, tagging, and interoperability for regulatory reporting and disclosures, requiring firms to shift from document-centric to **machine‑readable, standardized data** across multiple reporting regimes.
What Changed
- - The SEC, jointly with seven other U.S. financial regulators, has established mandatory technical data standards for information submitted to those agencies pursuant to the Financial Data...
- The joint standards apply to regulatory data collections within each participating agency’s remit (e.g., SEC filings and reports, certain prudential and market data submissions), and are intended to...
- The rule requires use of structured, non‑proprietary, machine‑readable formats (such as XML, JSON, XBRL, or similar open standards) where data is collected electronically, moving away from...
- The standards require use of public, non‑exclusive data dictionaries and taxonomies, so that data elements (e.g., fields, metrics, identifiers) are consistently defined and tagged across different...
- The rule embeds interoperability requirements, so that the same data element (for example, a LEI, CUSIP, counterparty ID, asset class, or exposure type) is reported using harmonized definitions and...
Suggested Considerations
- Conduct a comprehensive mapping of all current and upcoming regulatory data submissions to the SEC and other FDTA‑covered agencies to identify which reports are likely to be brought under the joint data standards.
- Review and update data governance frameworks so that key data elements (counterparty identifiers, instrument identifiers, balances, exposures, classifications) are uniquely defined, consistently sourced, and traceable across internal systems in alignment with anticipated joint taxonomies.
- Assess existing regulatory reporting systems and vendor solutions (including XBRL tools, data warehouses, and filing platforms) and develop an upgrade plan to support the new machine‑readable, standardized formats and schemas.
- Establish an internal FDTA/joint data standards implementation program, with clear ownership (e.g., finance, regulatory reporting, data management, IT) and a cross‑functional steering committee to oversee design, testing, and rollout.
- Engage with technology, regtech, and data vendors to confirm their timelines for supporting the new SEC and cross‑agency standards and to obtain updated taxonomies, schemas, and validation rules as soon as they are published.
Key Dates
– SEC press release date and effective date of the joint data standards rule (exact calendar date to be taken from the final rule and press release)
– SEC and other participating agencies publish technical specifications, schemas, and implementation guides for specific forms and data collections that will transition to the joint data standards
– Phased compliance dates for particular reporting forms and regimes as each agency completes its implementation plans under the FDTA; individual forms will have distinct first‑applicable reporting periods and transition windows
Compliance Impact
The impact is high, because the rule drives structural changes to how regulatory data is formatted, governed, and submitted, with material systems and process implications across multiple reporting regimes. Non‑compliance may result in rejected filings, late‑filing violations, enforcement risk, and increased scrutiny over the accuracy and reliability of reported data.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer No description available.
All Firms
The Securities and Exchange Commission today announced five new members of the Small Business Capital Formation Advisory Committee. The new members were appointed to four-year terms and will join the 15 current …
All Firms
No description available.
The CFTC has rescinded its long‑standing **“no-deny” settlement policy** in Appendix A to Part 10, which had barred settlements where defendants wished to continue denying the Commission’s allegations. This change applies **both prospectively and retrospectively**, as the CFTC will no longer enforce existing no‑deny provisions in prior settlements, materially altering settlement dynamics, post‑settlement communications, and reputational risk management for CFTC‑regulated entities.
What Changed
- - The CFTC has rescinded the policy in Appendix A to Part 10 that prevented the Commission from accepting settlement offers where a respondent or defendant continued to deny the allegations in a...
- The CFTC will now accept settlements even where the settling party publicly denies or continues to deny the CFTC’s allegations, provided other settlement terms are satisfied.
- The CFTC has stated that it will not enforce existing no-deny (neither‑admit‑nor‑deny) provisions in settlements that have already been entered.
- If a settling party breaches an existing no-deny provision, the CFTC will not allege breach of contract, seek to reopen the matter, ask a district court to vacate the settlement, or reopen an...
- The rescission does not alter the CFTC’s discretion to:
- settle with defendants who decline to admit facts or liability; or
- negotiate and require admissions of facts or liability in...
Suggested Considerations
- Review all existing CFTC settlement orders, consent orders, and related agreements to identify any no‑deny or neither‑admit‑nor‑deny clauses and update internal records to reflect that the CFTC has stated it will not enforce those provisions.
- Update internal enforcement and litigation playbooks to incorporate the new settlement flexibility, including explicit guidance that public denials post‑settlement may be possible but should be subject to legal and reputational risk review.
- Revise board- and senior‑management reporting on CFTC enforcement risks and settlement strategy to reflect the rescission of the no‑deny policy and the availability of settlements without waiving the ability to contest allegations in public communications.
- Implement or update communications and investor‑relations protocols governing post‑settlement statements, ensuring any public denials or clarifications are coordinated with legal, compliance, and, where relevant, parallel regulators or criminal authorities.
- For ongoing CFTC investigations or settlement negotiations, instruct external and internal counsel to reassess settlement strategy, including whether to seek terms that preserve the firm’s ability to deny or contest aspects of the CFTC’s allegations after settlement.
Key Dates
– CFTC adopts Appendix A to Part 10, establishing the policy of not accepting settlements where the respondent or defendant continues to deny the allegations
– Federal Register publication date referenced in the CFTC’s final rule rescinding Appendix A to Part 10 (Rescission of Policy Regarding Denials in Settlements of Enforcement Actions, 91 FR 29892)
– CFTC issues Press Release 9247‑26 publicly announcing that it has rescinded the policy and will not enforce existing no‑deny provisions
– The rescission of Appendix A to Part 10 becomes effective as a final rule upon publication in the Federal Register; from this date, the CFTC will not apply the no‑deny policy in new settlements and will not enforce existing no‑deny clauses
Compliance Impact
Non‑compliance arises less from violating the rescinded policy itself and more from mismanaging post‑settlement communications, which may create new litigation, regulatory, or disclosure risks if statements are misleading, inconsistent with other settlements, or inaccurate. Failure to update settlement and communications practices could undermine risk management, investor confidence, and relationships with multiple regulators, even if formal CFTC sanctions for “breaching” past no‑deny clauses are no longer expected.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerAsset ManagerHedge Fund No description available.
Crypto ExchangeBroker Dealer
The Securities and Exchange Commission today published a Draft Strategic Plan that focuses on returning the agency to the core mission set by Congress more than 90 years ago: protecting investors; maintaining fair, orderly, and efficient…
The SEC has issued a **Draft Strategic Plan for public comment** that sets out three agency-wide priorities: refocusing regulation on investor protection, market efficiency, and capital formation; improving stakeholder engagement and compliance facilitation; and modernizing internal operations and technology. For compliance teams, this matters because it signals where the Commission may concentrate rulemaking, examinations, enforcement, and disclosure modernization over the planning horizon.
What Changed
- - The SEC is proposing a strategic reorientation toward core statutory objectives: investor protection, fair and orderly markets, and capital formation.
- The plan emphasizes clearer, fit-for-purpose rules intended to support innovation while deterring misconduct.
- The SEC says it will prioritize modernizing and simplifying disclosure practices, which may affect reporting frameworks and issuer-facing compliance processes.
- The draft plan highlights expanded access to private markets and new capital-raising pathways, signaling possible future changes in offering, exemptive, and disclosure regimes.
- The SEC identifies digital assets and distributed ledger technologies as an area needing a “firm regulatory foundation,” indicating continued policy development for crypto-related activities.
Suggested Considerations
- Submit written comments by 02 July 2026 if your firm wants to influence the SEC’s strategic priorities, especially on disclosure modernization, private markets, digital assets, or enforcement posture.
- Include File Number DSP-3 on all comments and use only one submission method, because the SEC requires the file number on email subject lines and asks commenters to choose a single channel.
- Review internal compliance roadmaps for likely impacts from disclosure simplification, rule retrospectives, and enforcement refocusing, and identify where current controls may become redundant or need redesign.
- Assess whether your firm’s digital asset, tokenization, or distributed ledger activities may benefit from future SEC guidance or may face new framework requirements.
- Monitor developments on EDGAR modernization and filing technology changes, and test whether internal reporting, tagging, or submission processes would need upgrades.
Key Dates
- Deadline for submitting public comments on the Draft Strategic Plan
Compliance Impact
The immediate legal risk is low because this is a consultation document, not a binding rule, but the strategic direction is important for supervisory planning, examination priorities, and future rulemaking. Firms that fail to engage or prepare may face higher remediation costs later if the SEC follows through on disclosure, enforcement, or technology changes.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
All FirmsAsset ManagerBroker Dealer No description available.
Broker DealerAll Firms
No description available.
The CFTC has implemented a technical enhancement to its electronic Portal system that allows exchanges to submit a single set of product self‑certification documents covering multiple closely related contracts in one consolidated filing. This matters for compliance teams at CFTC‑registered exchanges because it changes the *operational* process for Part 40 product submissions, reduces duplicative documentation, and will require updates to internal procedures, templates, and controls governing self‑certifications.
What Changed
- - The CFTC Portal now supports consolidated product self‑certification submissions, enabling exchanges to file a single set of certification documents that apply to multiple closely related contracts...
- Exchanges are no longer required to upload multiple identical copies of supporting product certification documents when listing several closely related contracts; one shared documentation set can be...
- The enhancement is framed as an administrative/technical change to the filing process; it does not alter substantive legal standards for product self‑certification under the Commodity Exchange Act or...
- The CFTC has issued updated submission instructions on the Portal site specifying how to use the new consolidated filing functionality, including formatting and process guidance.
- Dedicated technical and non‑technical CFTC contacts have been identified (Howard Rosen for system use; Chris Goodman for product submission process questions), signaling that the Commission expects...
Suggested Considerations
- Review and obtain the updated submission instructions on the CFTC Portal and ensure legal, compliance, and operations staff understand the consolidated filing functionality and any new formatting or data‑entry requirements.
- Update internal product approval and submission procedures (including Part 40 playbooks and checklists) to reflect the ability to file a single set of documents for multiple closely related contracts, and to define when consolidation is appropriate.
- Revise internal documentation templates (e.g., product term sheets, legal analyses, core principle compliance memos, risk assessments) so that they can explicitly support multiple closely related contracts in a single package where relevant.
- Adjust governance workflows (approvals, sign‑offs, and quality checks) so that:
- Each contract included in a consolidated submission is clearly identified and traceable, and
Key Dates
– Executive Order 14243 is issued, setting an administrative objective to eliminate bureaucratic duplication and inefficiency, which this CFTC enhancement is designed to support
– CFTC announces and launches the Portal enhancement permitting consolidated product self‑certification submissions for multiple closely related contracts
Compliance Impact
Non‑compliance with the updated filing process is unlikely to result in direct enforcement, but incorrect or incomplete use of consolidated submissions could delay product listings, prompt CFTC information requests, or lead to questions regarding the adequacy and completeness of self‑certification packages. Over time, persistent deficiencies in product submissions could increase regulatory scrutiny of a venue’s compliance controls and governance around new product listings.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager The Securities and Exchange Commission today announced four new members to fill vacancies on its Investor Advisory Committee. Three of the four new members will serve four-year terms, while the fourth new member will serve as the…
All Firms
No description available.
All Firms
No description available.
Crypto ExchangeBroker Dealer
The Securities and Exchange Commission today proposed the rescission of overly burdensome and costly rules that require companies to provide certain climate-related information in their registration statements and annual reports. The Commission’s…
The SEC has issued a **proposal to rescind its climate‑related disclosure rules** that currently require registrants to provide specified climate information in registration statements and Form 10‑K‑type annual reports. If finalized, this would materially reduce prescriptive federal climate disclosure obligations, but compliance teams must carefully manage the transition because existing rules remain in force until any rescission is adopted and effective, and investors, proxy advisors, and other regimes (notably EU and state-level) will still expect robust climate disclosure.
What Changed
- - The SEC proposes to rescind the 2024–2025 climate‑related disclosure rules that mandated detailed climate information in Securities Act registration statements and Exchange Act annual reports,...
- The proposal would remove line‑item requirements for climate‑related governance and oversight by the board and management that had been added to Regulation S‑K and related forms.
- The proposal would eliminate prescriptive disclosure of climate‑related risks over specified time horizons (short, medium, long term) and their impacts on strategy, business model, and outlook that...
- The proposal would rescind obligations to provide certain climate‑related financial metrics in audited financial statements, including disaggregation of climate‑related impacts in footnotes, thereby...
- The proposal would eliminate any mandatory greenhouse gas (GHG) emissions disclosures that were part of the climate rules, including Scopes that were required for large filers, returning GHG...
Suggested Considerations
- Maintain full compliance with the existing SEC climate‑related disclosure rules in registration statements and annual reports until a final rescission (if any) becomes effective, and do not scale back disclosures based solely on the proposal.
- Prepare internal briefing materials for the board, audit committee, and senior management explaining the proposed rescission, its potential implications, and the need to maintain current disclosures in the interim.
- Coordinate with legal, finance, sustainability, and investor relations teams to develop a contingency disclosure strategy that anticipates both outcomes: (i) rescission is finalized and prescriptive line items disappear, or (ii) the rule is modified or retained following comments or litigation.
- Review and update risk factor, MD&A, and business section drafting guidance to ensure that material climate‑related risks and opportunities continue to be addressed under general disclosure standards even if specialized climate items are removed.
- Engage external counsel and proxy‑advisory or ESG stakeholders to assess how reduced prescriptive SEC climate requirements will interact with EU, UK and state‑level climate disclosure regimes, and align internal reporting processes to meet the most stringent applicable framework.
Key Dates
– Potential SEC adoption of a final rule rescinding, modifying, or replacing the climate‑related disclosure rules, subject to consideration of comments and potential legal challenges
– SEC issues press release and proposing release announcing the proposed rescission of the climate‑related disclosure rules and opens the public consultation
– Public comment period expected to close a set number of days (typically 30–60) after publication of the proposing release in the Federal Register; the precise date will be specified in the Federal Register notice
– Effective date of any final rescission; compliance with the existing climate rules would continue to be required for reporting periods and filings before this date
Compliance Impact
Non‑compliance remains significant because, until any rescission is effective, issuers are expected to meet existing climate disclosure requirements and can face enforcement, private litigation, and restatement risk for material misstatements or omissions. Even after rescission, climate‑related statements will remain subject to the antifraud provisions of the federal securities laws and to scrutiny from investors, proxy advisors, and other regulators.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank No description available.
The CFTC has issued a policy statement confirming that **perpetual contracts listed as futures on designated contract markets (DCMs) will be subject to case‑by‑case review under CFTC Regulation 40.3**, rather than being treated as a standard product class. The trigger is a contemporaneous CFTC order allowing a DCM to list a bitcoin spot‑referencing perpetual contract as a futures contract, while clarifying that perpetuals on other asset classes are not automatically covered and must be submitted for prior Commission review.
What Changed
- - The CFTC formally recognizes that perpetual contracts may be listed as “futures contracts” by DCMs, as evidenced by an order permitting listing of a perpetual contract referencing the spot price of...
- The Commission states that perpetual contracts have “unique characteristics” that vary by underlying asset, and therefore they will not be treated as a homogeneous product category for listing...
- For perpetual contracts referencing asset classes not covered by the contemporaneous bitcoin perpetual order, the Commission indicates that the appropriate path is a case‑by‑case review under CFTC...
- The policy statement signals that DCMs should expect closer CFTC scrutiny of perpetual contract design, including settlement mechanisms and underlying market integrity, before new perpetuals (beyond...
- The statement confirms that it is a policy statement rather than a binding rule, but it effectively sets Commission expectations for how DCMs must approach the listing of perpetual contracts going...
Suggested Considerations
- DCMs intending to list new perpetual contracts must route proposed products that are not clearly covered by the existing bitcoin perpetual order through a Commission Regulation 40.3 case‑by‑case review process, and should build internal product‑approval workflows accordingly.
- DCMs must enhance their surveillance, market‑integrity, and risk‑management frameworks for perpetual contracts, including monitoring of the referenced spot market, funding‑rate or cash‑flow mechanisms, and potential manipulation vectors stemming from the underlying asset.
- FCMs and clearing members should identify client exposure to perpetual futures, review margin models and risk limits, and ensure that risk disclosures, product descriptions, and account‑opening documentation accurately reflect the regulatory status and unique risks of perpetual futures.
- Compliance teams at DCMs and intermediaries should update policies and procedures for new product approval, explicitly flagging perpetual contracts as requiring heightened CFTC engagement and governance review before listing.
- Legal and regulatory affairs teams should brief senior management and boards on the policy statement, emphasizing that future perpetual contracts on non‑bitcoin or non‑covered asset classes carry additional regulatory scrutiny and potential delays due to the required case‑by‑case review.
Key Dates
– CFTC issues the policy statement on listing of perpetual contracts and an order permitting a DCM to list a perpetual futures contract referencing the spot price of bitcoin
– Policy statement is published in the Federal Register; from that point, DCMs and market participants can treat it as the Commission’s formal articulation of expectations for perpetual contract listings
Compliance Impact
Non‑compliance with the Commission’s articulated expectation to use Regulation 40.3 review for perpetual contracts outside the scope of the bitcoin perpetual order could lead to CFTC objections to product listings, enforcement actions, or mandated contract modifications or delistings. The impact is medium‑to‑high for DCMs and intermediaries involved in perpetual products, given the direct effect on product strategy, time‑to‑market, and potential litigation or supervisory risk if perpetuals are listed or operated inconsistently with the policy statement.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Crypto ExchangeBroker DealerHedge Fund No description available.
Broker DealerCrypto Exchange
No description available.
Crypto Exchange
No description available.
Broker DealerCrypto Exchange
No description available.
The CFTC has intervened in federal court in Rhode Island to block the state from enforcing its gambling laws against a CFTC‑registered designated contract market (DCM) offering prediction/event contracts. This action is a direct assertion of the CFTC’s exclusive jurisdiction under the Commodity Exchange Act (CEA) over event contracts and CFTC‑registered prediction markets, with significant implications for how exchanges, intermediaries, and market participants manage state law risk and venue selection.
What Changed
- - The CFTC has formally sought to intervene in a U.S. District Court case in Rhode Island to halt the state’s attempt to apply state gambling laws and seek civil penalties against a CFTC‑registered...
- The Commission has publicly reaffirmed that event contracts traded on CFTC‑registered exchanges are “commodity derivatives” squarely within the CFTC’s regulatory remit under the Commodity Exchange...
- The CFTC is explicitly characterizing its authority over CFTC‑registered prediction markets as “exclusive jurisdiction,” signaling that state gambling regulators and attorneys general should not...
- The Rhode Island dispute is identified as part of a broader pattern of state challenges to CFTC jurisdiction over prediction markets, following similar or related litigation in Arizona, Connecticut,...
- The enforcement posture indicates that CFTC‑registered contract markets facing state actions can expect active CFTC litigation support when states attempt to apply gambling or gaming statutes to...
Suggested Considerations
- Review current and planned event or prediction‑market contracts to confirm that they are structured, documented, and marketed as commodity derivatives under the Commodity Exchange Act rather than as gaming or wagering products.
- Update internal legal and compliance memoranda on federal preemption and CFTC “exclusive jurisdiction” to reflect the CFTC’s latest public position and the ongoing Rhode Island and related state cases.
- Map state‑law exposure for event contracts by conducting a jurisdictional sweep of gambling, gaming, bucket‑shop, and “games of chance” statutes for key states where customers or operations are located, with particular focus on Rhode Island, Arizona, Connecticut, Illinois, New York, and Minnesota.
- Enhance product‑approval and new‑business committees’ procedures so that, before launching event contracts, they explicitly document CEA coverage, CFTC oversight, and a preemption analysis versus relevant state gambling laws.
- For CFTC‑registered contract markets, establish and maintain a litigation and regulatory‑strategy playbook for responding to state attorney‑general investigations or enforcement demands, including criteria for when to seek CFTC support or intervention.
Key Dates
– A CFTC‑registered designated contract market files a federal complaint after being threatened with impending state enforcement under Rhode Island gambling laws
– Rhode Island files a parallel state‑court complaint seeking significant civil penalties and demanding that prediction markets “stand down” and “disgorge their profits.”
– The CFTC files a motion to intervene in the U.S. District Court for the District of Rhode Island to block state enforcement and reiterate its claim of exclusive jurisdiction over CFTC‑registered prediction markets
Compliance Impact
Non‑compliance with CEA and CFTC requirements, or misalignment with the CFTC’s asserted exclusive jurisdiction, could expose firms to overlapping enforcement from both federal and state authorities, including significant civil penalties, injunctive relief, forced cessation of business, and profit disgorgement. Firms failing to anticipate and manage the federal–state conflict risk may also face abrupt business interruption, litigation costs, and reputational damage in the rapidly evolving prediction‑market space.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerFintechCrypto Exchange No description available.
Crypto Exchange
No description available.
Crypto Exchange
The Securities and Exchange Commission’s Investor Advisory Committee will hold a public meeting at the SEC Headquarters in Washington D.C. on June 4 at 10 a.m. ET to discuss private markets, passive index funds, and recommendations regarding fund…
Asset ManagerBroker Dealer
No description available.
Broker DealerAll Firms
The Securities and Exchange Commission (SEC) and National Futures Association (NFA) today announced that they have entered into a Memorandum of Understanding (MOU) to enhance their cooperation, coordination, and information sharing in areas of common…
All Firms
No description available.
On 19 May 2026, the CFTC Division of Enforcement issued a new cooperation advisory that supersedes all prior CFTC cooperation and self‑reporting advisories and policies. For compliance teams, this resets the playbook for how voluntary self‑reporting, cooperation, remediation, and restitution/disgorgement are assessed for mitigation credit, including a clarified path to potential declinations where specific conditions are met.
What Changed
- - The CFTC Division of Enforcement has adopted a new, unified cooperation policy that expressly supersedes all prior Division cooperation and self‑reporting advisories (including the 2017 corporate...
- The new advisory establishes a clear “declination pathway” under which, absent aggravating circumstances, a respondent that voluntarily self‑reports, fully cooperates, timely and appropriately...
- The advisory formalizes that voluntary self‑reporting is a central prerequisite for the highest level of credit, distinguishing between cases with self‑reports (potential declination or high...
- The policy confirms that “full cooperation” will be a necessary condition for a declination, which in practice will require proactive, resource‑intensive engagement with Enforcement beyond mere...
- The advisory codifies that timely and appropriate remediation is a separate and indispensable requirement for top‑tier outcomes, emphasizing that firms must implement corrective measures before...
Suggested Considerations
- Identify and catalogue all existing internal policies, playbooks, and checklists relating to CFTC investigations, dawn raids, inquiries, self‑reporting, and cooperation, and amend them to reflect the new advisory’s superseding status.
- Update the firm’s enforcement‑response framework to explicitly incorporate the new declination pathway, including clear decision criteria for when and how to voluntarily self‑report potential CFTC violations.
- Establish or refine escalation triggers for potential insider trading, fraud, manipulation, and market abuse in CFTC‑regulated markets to ensure that issues can be investigated and elevated quickly enough to support “prompt” and “voluntary” self‑reporting.
- Design and document a structured internal investigation protocol that can generate the level of factual development, analysis, and documentation needed to demonstrate “full cooperation,” including protocols for sharing findings, data, and analytics with the CFTC where appropriate.
- Implement procedures to rapidly secure, preserve, and collect relevant trading records, communications (including messaging apps), surveillance alerts, and algorithmic trading data so that the firm can cooperate effectively and avoid any appearance of obstruction or delay.
Key Dates
- CFTC Division of Enforcement issues the new cooperation advisory, which supersedes all prior cooperation and self‑reporting advisories and becomes the operative policy for ongoing and future enforcement matters
Compliance Impact
The impact is high: the advisory reshapes incentives around self‑reporting and cooperation and directly affects whether firms can obtain declinations or material penalty reductions in CFTC enforcement actions. Failure to align investigation, remediation, and reporting practices with the new framework may result in higher civil monetary penalties, loss of declination eligibility, and more intrusive enforcement scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerAsset ManagerHedge Fund The Securities and Exchange Commission today proposed amendments to its rules and forms governing registered offerings that are designed to increase efficiency, flexibility, and cost savings for public companies while maintaining robust investor…
The SEC has issued a proposing release, “SEC Proposes Transformative Reforms to Help Public Companies Conduct Registered Offerings and Simplify Reporting Requirements,” that would overhaul key aspects of the Securities Act of 1933 registered offering framework and associated Exchange Act reporting. The proposal is aimed at streamlining shelf registration, communications, and periodic reporting to reduce cost and friction for seasoned public companies while preserving core disclosure and liability safeguards, so issuer compliance teams will need to reassess their entire offering and disclosure playbook if the rules are adopted.
What Changed
- *(Based on the SEC’s description and consistent with prior offering‑reform initiatives; specific rule and form cites will need to be confirmed against the proposing release once reviewed in full.)*
- The SEC proposes to modernize the shelf registration process for Form S‑3 and F‑3 issuers, including expanded use of automatic or “universal” shelves and greater flexibility to add classes of...
- The proposal would streamline incorporation by reference, allowing more categories of Exchange Act reports and exhibits to be incorporated into Securities Act registration statements and prospectuses...
- The SEC proposes to expand the use of “access equals delivery” for final prospectuses, permitting issuers in additional circumstances to satisfy Securities Act Section 5(b)(2) delivery requirements...
- The reforms would broaden the range of permissible communications in connection with registered offerings, including issuer and underwriter use of certain factual and forward‑looking information,...
Suggested Considerations
- Monitor the Federal Register and SEC website for the full proposing release text and the precise comment deadline for this rulemaking.
- Coordinate among legal, finance, and investor relations teams to prepare and submit a comment letter to the SEC addressing practical implications of the proposed offering and reporting reforms for your issuer, including any concerns about liability, operational feasibility, and investor impact.
- Inventory all existing shelf registration statements (including automatic shelves), universal shelves, and continuous‑offering programs and identify where proposed changes to shelf mechanics, incorporation by reference, or prospectus updating could affect structure, timing, or disclosure.
- Review current offering communication practices, including use of free writing prospectuses, roadshow materials, and research reports, and map them against the proposed expanded communications safe harbors to determine what additional flexibilities could be used in future offerings.
- Assess your firm’s use of Exchange Act reports incorporated by reference into Securities Act registration statements and plan to revise drafting and review procedures to take advantage of streamlined incorporation while managing Securities Act liability for incorporated information.
Key Dates
– Federal Register publication of the SEC proposing release “SEC Proposes Transformative Reforms to Help Public Companies Conduct Registered Offerings and Simplify Reporting Requirements,” starting the formal comment period
– End of SEC comment period (typically 30–60 days after Federal Register publication; exact deadline to be confirmed in the notice)
– Potential adoption of final rules by the SEC, following review of comment letters
– Final rules become effective on a date specified in the adopting release (often 30–60 days after Federal Register publication of the final rules)
– Staggered or delayed compliance dates for specific form and disclosure changes, expected to give registrants time to update registration statements, shelf programs, and periodic reporting templates
Compliance Impact
Because the proposal seeks mainly to reduce friction and modernize existing processes rather than impose new prohibitions, the risk of traditional “non‑compliance” arises primarily from failing to adapt offering and disclosure practices to the updated framework, potentially leading to inefficient capital‑raising, errors in form usage, or Securities Act liability from misapplied incorporation and communication rules. Issuers and intermediaries that do not update their procedures once rules are finalized could face increased regulatory scrutiny, offering delays, or remedial filings.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager No description available.
Broker DealerAll Firms
The Securities and Exchange Commission today rescinded a policy, codified in Rule 202.5(e) of its informal rules of procedures, stating that when it chooses to settle an enforcement action in which a sanction is imposed, it will not settle unless the…
The SEC has rescinded its long‑standing “no‑deny” settlement policy, previously codified in Rule 202.5(e) of the Commission’s Rules of Practice, which had prohibited settling respondents from publicly denying the Commission’s allegations in cases resolved on a “neither admit nor deny” basis. This materially alters how firms can speak about resolved SEC enforcement matters and will directly affect settlement negotiations, collateral consequences analysis, and post‑settlement communications and disclosure strategies.
What Changed
- - The SEC has rescinded the policy in Rule 202.5(e) of its informal Rules of Practice that conditioned settlements involving sanctions on the respondent’s agreement not to publicly deny the...
- Settling parties in SEC enforcement actions may now have greater scope to make public statements that deny or contest aspects of the SEC’s allegations, subject to the specific language of each...
- The traditional “neither admit nor deny” construct will no longer automatically include a built‑in prohibition on denials, which means the SEC staff will need to negotiate any desired limitations on...
- Communications and disclosure provisions in SEC settlement papers (including “undertakings” and clauses governing press releases and investor communications) are likely to become more tailored and...
- The rescission increases the importance of alignment between legal, compliance, and communications teams when crafting public statements following an SEC settlement, because statements that deny...
Suggested Considerations
- Review existing internal playbooks for handling SEC investigations and settlements and update them to reflect the rescission of Rule 202.5(e), including how settlement language on admissions, denials, and public statements is negotiated.
- For matters currently under SEC investigation or in active settlement negotiations, direct outside and in‑house counsel to reassess settlement strategy, including whether to seek greater flexibility for post‑settlement denials or clarifications in the consent language and undertakings.
- Conduct an inventory of significant historical SEC settlements that included “no‑deny” provisions and identify where ongoing communications plans, disclosure narratives, or litigation strategies may be constrained by legacy language.
- For high‑impact historical orders with restrictive “no‑deny” clauses, obtain legal advice on whether and how to approach the SEC about potential modification or clarification of those provisions in light of the Commission’s changed policy.
- Train senior management, board members, and spokespersons on the revised SEC posture, emphasising that while denials may now be more permissible, inaccurate or overly aggressive denials could adversely affect ongoing private litigation, insurance recoveries, or relationships with other regulators.
Key Dates
- The SEC issues the press release announcing rescission of its “no‑deny” policy codified in Rule 202.5(e), signalling immediate policy change for new enforcement settlements
- Any subsequent SEC guidance, FAQs, or amendments to the Rules of Practice or Enforcement Manual that clarify how post‑settlement denials will be treated in future cases may be issued at a later date
Compliance Impact
Non‑compliance will not typically arise from the policy rescission itself, but from making public statements that conflict with specific settlement terms, are misleading to investors, or undermine other legal obligations. Missteps in this area can trigger renewed SEC scrutiny, private securities litigation exposure, reputational damage, and potential challenges with insurers and other regulators.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank No description available.
All Firms
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All Firms
The Securities and Exchange Commission today charged 21 individuals for their alleged involvement in a decade-long insider trading scheme that used information misappropriated from multiple global law firms and resulted in millions of dollars in illicit…
Broker Dealer
Staff in the Securities and Exchange Commission’s Divisions of Investment Management and Corporation Finance issued guidance addressing certain questions regarding the application of the federal securities laws to pooled employer plans (PEPs), which help…
All Firms
The Securities and Exchange Commission today proposed rule and form amendments that would give public companies the option of filing semiannual reports in lieu of quarterly reports to meet their interim reporting obligations under the federal securities…
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All Firms
The Securities and Exchange Commission today announced that Jason Burt, Deputy Director of the Division of Enforcement (Specialized Units), will depart the agency on May 1, 2026, after more than 22 years of public service.“Jason’s exceptional leadership…
All Firms
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Broker Dealer
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments to reduce private fund reporting burdens while enabling the continued collection of necessary and appropriate information. The…
The SEC and CFTC have jointly proposed amendments to Form PF to reduce reporting burdens for private fund advisers by streamlining data requirements, simplifying calculations, and adjusting filing thresholds, while preserving essential information for systemic risk monitoring and investor protection. This matters for compliance professionals as it offers relief from prior expansions to Form PF (adopted in 2024), potentially lowering operational costs amid ongoing regulatory scrutiny, but requires monitoring during the comment period to influence final rules. https://www.sec.gov/newsroom/press-releases/2026-40-sec-cftc-jointly-propose-amendments-reduce-private-fund-reporting-burdens
What Changed
- - Streamlined Reporting Items: Amendments propose removing or simplifying certain Form PF fields, such as reducing detailed breakdowns of investment exposures, counterparty data, and performance...
- Adjusted Filing Thresholds: Raise thresholds for "large hedge fund advisers" and "large private equity advisers" (e.g., from $1.5B to potentially higher AUM levels for certain funds), limiting who...
- Simplified Calculations: Eliminate complex aggregation rules for master-feeder/parallel structures, revert to prior methods for inflows/outflows and AUM (e.g., no double-counting exclusions for...
- Event Reporting Relief: Propose delaying or narrowing 72-hour current event reporting (e.g., for large hedge funds under new Section 6), responding to burden complaints from 2024 amendments.
These...
Suggested Considerations
- Review Proposal: Download full proposing release post-Federal Register publication; assess current Form PF processes against proposed simplifications (e.g., audit AUM calculations, exposure schedules).
- Submit Comments: File detailed feedback by comment deadline, focusing on burden estimates, implementation feasibility, and alternatives (e.g., via SEC's online portal); prioritize if your firm files quarterly/detailed sections.
- Update Systems: Map current reporting workflows to proposed changes; pilot simplified data pulls for inflows, performance, and structures; prepare for potential transition rules if adopted.
- Monitor Extensions: Track related no-action relief (e.g., CFTC Letter 25-50 for interim burden reduction) and Form N-PORT extensions.
- Internal Training: Educate compliance teams on threshold changes and event reporting tweaks to avoid over-reporting during transition.
Key Dates
Extended compliance date for Names Rule-related Form N-PORT reporting (fund groups ≥$10B AUM); ; related relief via separate SEC action
Extended compliance date for Names Rule-related Form N-PORT reporting (fund groups <$10B AUM)
2026) - End of public comment period; ; proposing release to be published soon after April 2026 announcement
comment, est. late 2026/early 2027) - Adoption of final amendments; , subject to notice-and-comment revisions
Compliance Impact
Urgency: High – Proposals signal imminent relief from 2024 Form PF expansions (effective 2025+), which added significant burdens like 72-hour events and granular exposures, but firms must act on comments now (within ~60 days) to shape outcomes and avoid sunk costs in current systems. Matters because it reverses prior increases (e.g., separate master-feeder reporting, detailed strategies), potentially saving millions in annual external costs, but non-response risks locking in suboptimal rules amid FSOC scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerHedge Fund
No description available.
Asset ManagerHedge Fund
No description available.
All Firms
The Securities and Exchange Commission today announced the launch of Material Matters With SEC Chairman Paul Atkins, a new podcast that provides stakeholders and the investing public with exclusive interviews and insights around the agency’s policy and…
Asset ManagerBroker DealerWealth Manager The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee announced that it will hold a meeting on Tuesday, April 28, 2026 at 10:00 a.m. to explore ways to encourage more companies to go public.The meeting will be open…
Broker DealerFintech
The Securities and Exchange Commission today issued a concept release soliciting public comment in support of a comprehensive review of the Consolidated Audit Trail (CAT) and other audit trails and related data sources currently used in the regulation of…
Broker DealerAsset Manager
The Securities and Exchange Commission today issued a conditional exemptive order that permits customer cross-margining of cash market positions in U.S. Treasury securities cleared by a registered clearing agency and futures positions in U.S. Treasury…
The SEC has issued a conditional exemptive order and approved a proposed rule change by the Fixed Income Clearing Corporation (FICC) to enable customer cross-margining between cash U.S. Treasury positions cleared at FICC and futures positions cleared at the Chicago Mercantile Exchange (CME), extending a benefit previously limited to clearing members. This development enhances Treasury market liquidity and resilience by allowing dually registered broker-dealers/futures commission merchants (FCMs) to offer more efficient margin calculations to customers, aligning SEC and CFTC efforts in modernizing clearing infrastructure.
What Changed
- - Exemptive Order: Provides relief from the SEC's broker-dealer customer protection rule (Rule 15c3-3), permitting dually registered broker-dealer/FCMs that are joint clearing members of FICC and CME...
- Rule Change Approval: Approves FICC's filing to incorporate a Third Amended and Restated Cross-Margining Agreement with CME into its Government Securities Division rules, enabling cross-margining at...
- Scope Expansion: Shifts from prior restrictions where only clearing members could cross-margin, now extending to eligible customers of qualifying firms, with safeguards for customer fund segregation...
Suggested Considerations
- Qualifying Firms: Review and ensure compliance with exemptive order conditions (e.g., customer eligibility, account segregation, risk controls) before offering cross-margining; update internal policies, systems, and customer agreements to support combined margin calculations in futures accounts.
- Operational Updates: Implement changes to clearing and margining processes aligned with the Third Amended Cross-Margining Agreement; conduct testing with FICC and CME for customer-level arrangements.
- Documentation and Reporting: Maintain records demonstrating adherence to Rule 15c3-3 exemptions and notify customers of new margining options; monitor for CFTC parallel requirements on commingled funds.
- Legal/Compliance Review: Assess dual SEC/CFTC registration status and joint membership; consult with counsel on condition-specific interpretations.
Key Dates
- SEC issues conditional exemptive order and approves FICC's proposed rule change
April 15, 2026 (prior to Federal Register publication); - Exemptive order and rule approval made available on SEC.gov; related CFTC order on CFTC.gov
- Official effective date upon Federal Register publication (no specific comment or implementation deadline specified in announcement)
Compliance Impact
Urgency: High - This enables immediate operational opportunities for margin efficiency but requires swift review of systems and controls to meet conditional safeguards, avoiding customer protection violations under Rule 15c3-3. Firms risk regulatory scrutiny or missed liquidity benefits if unprepared, especially amid ongoing Treasury clearing mandates; proactive adoption supports market resilience goals without mandatory overhaul.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerHedge FundAsset Manager
No description available.
Broker DealerBank
No description available.
BankBroker DealerAsset Manager No description available.
The CFTC secured a U.S. District Court consent order on April 13, 2026, against Florida resident Emir Jesus Matos Camargo and his firm Aureus Revenue Group LLC for commodity pool fraud, including misrepresentations like a fake CFTC license and fund misappropriation, resulting in over $1.3 million in restitution and penalties plus permanent bans. This enforcement action underscores the CFTC's aggressive pursuit of fraud in commodity pools, particularly involving forged regulatory credentials, serving as a stark reminder for firms to verify all licensing claims and protect client funds. Compliance teams must prioritize misrepresentation controls to avoid similar liability, including controlling person exposure.
What Changed
- This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements.
- Fraud in futures trading (CEA Section 6(c), 7 U.S.C. § 9).
- Fraud by associated persons of commodity pool operators (CPAs) (CFTC Regulation 4.41(a)(1), 17 C.F.R. § 4.41).
- Acting as an unregistered commodity pool operator (CPO) (CEA Section 4m(1), 7 U.S.C. § 6m).
- Controlling person liability for firm violations (CEA Section 13(b), 7 U.S.C. § 13c(b)), as applied to Matos over Aureus.[https://www.cftc.gov/PressRoom/PressReleases/9212-26]
Suggested Considerations
- Registration verification: Confirm CPO/AP registration status via NFA BASIC (https://www.nfa.futures.org/basicnet/) before solicitations; prohibit any implication of CFTC "licensing" without proof.
- Marketing review: Audit all promotional materials for false claims (e.g., seals, signatures, fictitious licenses); require pre-approval by compliance.
- Fund segregation: Implement strict controls on pool participant funds, including third-party custody and daily reconciliations to prevent misappropriation.
- Controlling person policies: Document oversight duties for principals; conduct gap analyses for personal liability under CEA Section 13(b).
- Training: Mandatory annual training on CEA fraud provisions, with attestations.
Key Dates
- CFTC enforcement action filed against Matos and Aureus
- U.S. District Court for the Middle District of Florida enters consent order resolving claims against Matos (action against Aureus remains pending).[https://www.cftc.gov/PressRoom/PressReleases/9212-26]
Compliance Impact
Urgency: Medium - This action highlights ongoing CFTC enforcement trends in Florida commodity pool fraud but introduces no immediate mandates. It matters for CPOs and APs due to the precedent of high penalties ($666K restitution + $666K CMP, joint/several), permanent bans, and controlling person liability; firms with similar operations face elevated exam/audit risk, especially post-2024 filings. Proactive reviews now can mitigate whistleblower tips or NFA audits.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Asset ManagerHedge FundAll Firms
No description available.
The CFTC obtained a temporary restraining order (TRO) from the U.S. District Court for the District of Arizona on April 10, 2026, halting Arizona's criminal enforcement actions against CFTC-regulated designated contract markets (DCMs) offering prediction markets, following CFTC's lawsuit asserting exclusive federal jurisdiction under the Commodity Exchange Act. This development reinforces federal preemption over event contracts, preventing states from applying conflicting gambling or criminal laws, and matters because it shields compliant firms from state-level prosecution while broader litigation against Arizona, Connecticut, and Illinois proceeds. https://www.cftc.gov/PressRoom/PressReleases/9211-26
What Changed
There are no new regulatory requirements or changes imposed by this publication; instead, it documents a court-granted TRO that temporarily blocks Arizona's enforcement of state criminal and gambling laws against CFTC-regulated prediction markets, affirming CFTC's claimed exclusive jurisdiction over event contracts via federal preemption under the Commodity Exchange Act.
Suggested Considerations
- Monitor federal court dockets in the District of Arizona for updates on the preliminary injunction hearing and broader cases against other states.
- Document compliance with CFTC regulations for event contracts to demonstrate adherence to federal law in any state inquiries.
- Review state exposure for prediction market activities, pausing non-federal compliant operations in high-risk states like Arizona pending resolution.
- Enhance legal consultations on federal preemption defenses for ongoing or potential state enforcement. https://www.cftc.gov/PressRoom/PressReleases/9211-26
Key Dates
- Arizona files 20-count misdemeanor criminal case against prediction market platform Kalshi, alleging illegal gambling and election betting
- CFTC files complaints (with DOJ involvement) against Arizona, Connecticut, and Illinois seeking declaratory judgments on exclusive jurisdiction and permanent injunctions
- CFTC files motion for Temporary Restraining Order (TRO) and Preliminary Injunction in U.S. District Court for the District of Arizona to halt state enforcement
- U.S. District Court for the District of Arizona grants CFTC's requested TRO, barring Arizona from pursuing criminal charges against CFTC-regulated DCMs. (Note: Ongoing litigation timelines for preliminary injunction and permanent relief remain undetermined.)
Compliance Impact
Urgency: High - This rapidly evolving federal-state conflict, with a TRO granted just one day ago (April 10, 2026), creates immediate relief for Arizona-targeted firms but signals heightened litigation risk across states; compliance teams must prioritize jurisdictional mapping for prediction markets to avoid fragmented enforcement, as inconsistent state actions could expose firms to criminal liability despite federal compliance, potentially disrupting operations in a multi-state patchwork. The CFTC's aggressive stance underscores systemic risks from state "weaponization" of preempted laws.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerFintechCrypto Exchange
No description available.
FintechCrypto Exchange
No description available.
Broker DealerAll Firms
No description available.
The CFTC has filed a motion for preliminary injunction and temporary restraining order against Arizona, alongside coordinated lawsuits against Connecticut and Illinois, to halt state-level enforcement actions against CFTC-regulated prediction market operators. This escalating federal-state jurisdictional conflict centers on whether the Commodity Exchange Act grants the CFTC exclusive authority over prediction markets, preempting state gambling and criminal laws—a question that legal experts believe could ultimately reach the U.S. Supreme Court.
What Changed
- The CFTC's enforcement action establishes several critical legal positions:
- Federal Preemption Doctrine: The CFTC asserts that the Commodity Exchange Act grants it exclusive jurisdiction over event contracts and prediction markets, rendering state gambling laws inapplicable...
- Scope of Federal Authority: The CFTC claims "clear and longstanding exclusive jurisdiction" to regulate event contracts, positioning prediction markets as commodities derivatives rather than gambling...
- Injunctive Relief Sought: The CFTC is requesting both preliminary injunctions (immediate relief) and permanent injunctions (ongoing prohibition) preventing states from enforcing preempted laws...
- Declaratory Judgment Framework: The lawsuits seek court declarations that state gambling laws are "unconstitutional and invalid" if applied to prediction markets.
Suggested Considerations
- *For CFTC-Registered Prediction Market Operators:
- *Immediate Compliance Monitoring: Continue operating under CFTC registration while monitoring court proceedings; do not unilaterally cease operations in affected states pending injunction decisions.
- *Legal Coordination: Engage counsel to coordinate with CFTC enforcement efforts and provide evidence of compliance with federal registration requirements.
- *Documentation Preservation: Maintain comprehensive records demonstrating compliance with the Commodity Exchange Act and CFTC regulations to support the federal preemption argument.
- *State-Level Engagement: Respond to any outstanding cease-and-desist letters through counsel; do not ignore state enforcement communications, but assert federal preemption defenses.
Key Dates
- Arizona issued initial cease-and-desist letter to Kalshi
- Connecticut's Department of Consumer Protection issued cease-and-desist letters to Kalshi, Crypto.com, and Robinhood Derivatives
- Arizona filed criminal charges against Kalshi executives
- CFTC and DOJ filed coordinated lawsuits against Arizona, Connecticut, and Illinois
- CFTC filed motion for preliminary injunction and temporary restraining order in U.S. District Court for the District of Arizona
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
FintechBroker Dealer
The Securities and Exchange Commission today announced that David Woodcock has been appointed Director of the Division of Enforcement, effective May 4, 2026. Mr. Woodcock is currently a partner in the Dallas and Washington, D.C. offices of Gibson, Dunn…
The SEC has appointed David Woodcock, a Gibson Dunn partner and former SEC Regional Director, as the new Director of its Division of Enforcement, effective May 4, 2026, following the abrupt resignation of prior Director Margaret Ryan after six months. This leadership change signals a "significant course correction" under Chairman Paul Atkins, emphasizing investor protection and market integrity over prior aggressive enforcement approaches. Compliance professionals should monitor this closely, as it may shift enforcement priorities, potentially de-emphasizing certain areas like crypto crackdowns while intensifying focus on accounting fraud and financial reporting violations.
What Changed
There are no direct regulatory changes or new requirements in this announcement; it is a personnel appointment rather than a rulemaking or policy shift. However, SEC Chairman Atkins highlighted the Division's ongoing "course correction" to prioritize cases aligned with congressional intent for meaningful investor protection and market integrity, moving away from prior Gensler-era emphases. Woodcock's background in securities enforcement, financial reporting, and audit task forces suggests potential heightened scrutiny in those areas, though no specific mandates are outlined.
Suggested Considerations
- Review current exposure to SEC enforcement matters, particularly in financial reporting, accounting, and disclosures, in light of Woodcock's expertise.
- Monitor SEC announcements post-May 4, 2026, for signals on evolving priorities, such as reduced crypto focus or enhanced fraud detection.
- Enhance internal compliance training on investor protection and market integrity cases, aligning with the stated "course correction."
- Engage external counsel familiar with Woodcock's tenure (e.g., Gibson Dunn alumni or Fort Worth Regional Office veterans) for strategic advice.
Key Dates
- Prior Director Margaret Ryan resigned after approximately six months in the role amid reported disagreements on enforcement priorities
- David Woodcock assumes role as Director of the Division of Enforcement, succeeding Acting Director Sam Waldon
Compliance Impact
Urgency: Medium. This matters because leadership transitions at the Enforcement Division can reshape investigative priorities, resource allocation, and case selection for a team of over 1,000 professionals, influencing enforcement trends across securities violations. While not imposing new obligations, the shift from prior leadership—coupled with Atkins' emphasis on targeted investor protection—could reduce risks in deprioritized areas (e.g., crypto) but heighten them in core areas like accounting fraud, warranting vigilance ahead of the May 4 effective date.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerHedge Fund The Securities and Exchange Commission today announced enforcement results for the fiscal year that ended on September 30, 2025.Central to an effective enforcement program is determining which cases to bring and responsibly stewarding Commission…
The SEC's announcement details enforcement results for Fiscal Year 2025 (ended September 30, 2025), highlighting a significant slowdown in actions to 313 cases—the lowest in a decade—and $808 million in settlements, down 45% from FY 2024, amid leadership changes and a shift to "back-to-basics" priorities like retail investor protection. This matters for compliance professionals as it signals reduced enforcement volume under new Chair Paul Atkins, potential policy resets (e.g., crypto case dismissals), and a focus on core misconduct like fiduciary breaches and insider trading, influencing risk prioritization and resource allocation.
What Changed
- This is not a rulemaking publication introducing new regulations but an annual enforcement summary reflecting operational shifts rather than formal regulatory changes. Key developments include:
- Enforcement volume decline: 313 standalone actions (down 27% from 431 in FY 2024), with only 4 new actions against public companies post-January 20, 2025 (93% of 56 public company cases initiated...
- Monetary penalties reduced: $808 million in settlements (lowest since 2012) and record-low $108 million in disgorgement.
- Policy shifts: Dismissals of high-profile crypto cases (e.g., Coinbase, Binance); new task forces on crypto and cross-border fraud; emphasis on "bread-and-butter" cases like offering fraud, insider...
- Leadership and staffing impact: Post-Gensler transition (Uyeda as Acting Chair, Atkins sworn in April 2025); ~15% Enforcement staff reduction; record Q1 actions (200 total, October-December 2024)...
Suggested Considerations
- Review and strengthen controls around core risks: insider trading, offering fraud, fiduciary duties, and retail investor disclosures.
- Self-assess exposure to legacy Gensler-era cases, especially crypto-related, anticipating potential dismissals or settlements.
- Enhance self-reporting, remediation, and cooperation protocols, as SEC continues to credit these in resolutions.
- Monitor SEC task forces on crypto and cross-border fraud for emerging priorities.
- Update firm-wide risk assessments to deprioritize novel theories (e.g., shadow trading) in favor of traditional misconduct.
Key Dates
December 31, 2024; - FY 2025 Q1; record 200 enforcement actions filed
- Inauguration Day; marker for post-transition enforcement slowdown (only 4 public company actions afterward)
- Paul Atkins sworn in as SEC Chair
- End of FY 2025; period covered by the announcement
Compliance Impact
Urgency: Medium - This reflects a transitional slowdown and policy pivot rather than imminent threats or new rules, reducing short-term enforcement pressure but requiring strategic recalibration for sustained "back-to-basics" focus on investor protection. Matters due to signaling under new leadership: firms can reallocate resources from prior high-volume pursuits (e.g., crypto) to core compliance areas, but must prepare for targeted actions on fraud and fiduciary issues amid staffing changes.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerCrypto Exchange No description available.
BankBroker Dealer
The Securities and Exchange Commission today announced the agenda and panelists for its April 16, 2026, roundtable on options market structure.The roundtable will be held at the SEC’s headquarters at 100 F Street, N.E., Washington, D.C., from 9:00 a.m.…
Broker DealerAsset Manager
No description available.
Broker DealerFintech
No description available.
Hedge FundAsset Manager
No description available.
Crypto ExchangeFintech
No description available.
Broker DealerFintechCrypto Exchange
No description available.
This speech by CFTC Director of Enforcement David I. Miller outlines the Division's five core enforcement priorities for 2026—insider trading (especially in prediction markets), market manipulation, market abuse/disruptive trading, retail fraud, and willful AML/KYC violations—while announcing the end of "regulation by enforcement" and previewing a new cooperation policy with enhanced declination incentives. It matters because it signals a targeted, risk-based enforcement shift under Chairman Selig, emphasizing fraud detection over rulemaking, which demands immediate strengthening of surveillance, insider policies, and self-reporting in derivatives, crypto, and prediction markets. Firms face heightened scrutiny in these areas, with cooperation now explicitly tied to penalty mitigation.
What Changed
- - End of "regulation by enforcement": CFTC Enforcement will focus solely on policing fraud, abuse, and manipulation under existing CEA anti-fraud provisions, avoiding policy-setting via enforcement...
- Five explicit enforcement priorities:
1. Insider trading, with strong emphasis on prediction markets (e.g., misappropriation of nonpublic information violates CEA).
2.
- New cooperation policy advisory (forthcoming soon): Includes "significant changes" to declination policy, building on prior frameworks like mitigation-credit matrices and safe harbors for...
Suggested Considerations
- Enhance surveillance: Implement robust monitoring for insider trading in prediction markets, manipulation in energy, disruptive trading, retail fraud signals, and AML/KYC red flags; prioritize misappropriated nonpublic info detection.
- Update policies: Revise insider trading protocols to align with CEA anti-fraud provisions; train staff on prediction market risks (debunking "no insider laws apply" myth).
- Strengthen cooperation readiness: Develop self-reporting/escalation processes, remediation plans, and documentation for declination credit under forthcoming policy; review prior CFTC advisories (e.g., 2025 mitigation matrix).
- Conduct gap analysis: Audit AML/KYC programs for willful violations; assess exposure in priority markets (energy, prediction/crypto, retail).
- Monitor updates: Subscribe to CFTC Press Room for cooperation advisory and related actions (e.g., Feb 25, 2026 Prediction Markets Advisory post-enforcement cases: https://www.cftc.gov/PressRoom/PressReleases/9185-26).
Key Dates
Speech delivery; Outlines priorities and previews new cooperation policy advisory
New cooperation policy advisory issuance; Expected imminently; firms should monitor CFTC site for formal release
Compliance Impact
Urgency: High – This immediate post-appointment speech (March 31, 2026) sets 2026 priorities amid CFTC's expanding oversight of dynamic markets like prediction/crypto/swaps, with Director Miller's prosecutor background signaling aggressive pursuit of "serious violations." Firms risk enforcement in core fraud areas without proactive surveillance/cooperation; aligns with "back-to-basics" trends but elevates prediction market insider risks, demanding swift program updates to leverage new declination incentives.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerCrypto ExchangeAll Firms
The Securities and Exchange Commission’s Office of Investor Education and Assistance (OIEA) today announced that as part of April’s National Financial Literacy Month it will highlight financial planning tools and resources on Investor.gov to…
Asset ManagerBroker DealerWealth Manager No description available.
The U.S. District Court for the Southern District of New York entered a consent order on March 30, 2026, permanently enjoining Peken Global Limited (operator of KuCoin exchange) from allowing U.S. participants to access its platform without CFTC registration as a foreign board of trade (FBOT), imposing a $500,000 civil penalty. This enforcement action resolves CFTC claims from a March 2024 complaint, highlighting CFTC's focus on unregistered digital asset derivatives trading accessible to U.S. users. It matters for compliance professionals as it reinforces registration and access restriction requirements for foreign crypto platforms, amid parallel criminal resolutions and international penalties.
What Changed
- - Permanent Injunction: Peken Global is barred from future violations, specifically prohibiting U.S. participants from direct trading on its electronic trading and order-matching system without FBOT...
- Civil Penalty: $500,000 payment required; no disgorgement sought due to cooperation in CFTC investigation and related criminal proceedings (United States v. Flashdot Limited, et al., No.
- Dismissals: Voluntary dismissal with prejudice of all claims against Mek Global Limited, PhoenixFin PTE Ltd., and Flashdot Limited; dismissal of CFTC complaint counts II-V against Peken Global,...
- No new broad regulatory rules, but underscores CEA violations for off-exchange commodity futures, leveraged retail transactions, and unregistered FCM/SEF/DCM operations.
Suggested Considerations
- Verify Registration Status: Foreign platforms must confirm CFTC registration as FBOT if offering direct access to U.S. participants for futures/swaps/derivatives; implement geo-blocks or KYC to exclude U.S. users.[1 from provided content]
- Restrict U.S. Access: Proactively block U.S. IP addresses, require attestations of non-U.S. residency, and monitor for circumvention.
- Pay Penalties: Peken Global must remit $500,000 civil penalty per court order.
- Enhance Supervision/CIP: Implement effective customer identification programs (CIP) and supervision of activities, avoiding off-exchange leveraged retail commodity transactions.
- Monitor Affiliates: Dissolved entities (e.g., Mek Global, PhoenixFin) or non-operational parents (Flashdot) should ensure no residual U.S. exposure.
Key Dates
CFTC files civil enforcement complaint; against Peken Global and affiliates for CEA violations (Press Release 8884-24)
FINTRAC imposes $19,552,000 penalty; on Peken Global (KuCoin) for Canadian AML failures (failure to register, report large virtual currency transactions, submit suspicious transaction reports)
U.S. District Court enters consent order; imposing injunction, penalty, and dismissals.[1 from provided content]
Compliance Impact
Urgency: High – This immediate injunction sets a precedent for CFTC enforcement against unregistered foreign crypto exchanges serving U.S. users, with penalties despite cooperation and parallel criminal resolutions (e.g., guilty plea to unlicensed money transmitting). It signals heightened scrutiny on digital asset derivatives, urging proactive access controls to avoid similar $500k+ penalties, dismissals notwithstanding, especially post-2024 charges and 2025 FINTRAC action.[1 from provided content]
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Crypto ExchangeBroker Dealer
The Securities and Exchange Commission today approved an amendment to the National Market System Plan governing the Consolidated Audit Trail (“CAT”) and provided exemptive relief from certain requirements of Rule 17a-1 under the Securities Exchange Act…
Broker DealerAll Firms
No description available.
Broker DealerAll Firms
No description available.
FintechCrypto Exchange
No description available.
Broker DealerFintechCrypto Exchange
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerAsset Manager
No description available.
The CFTC issued FAQs on March 20, 2026, providing clarification on how registered entities and market participants should handle crypto assets and blockchain technologies in their operations, building directly on the agency's tokenized collateral guidance and no-action relief issued in late 2025 and early 2026. This guidance is critical because it operationalizes the SEC-CFTC joint interpretation issued just three days earlier (March 17, 2026), which established a binding regulatory framework classifying 16 crypto assets as digital commodities and clarifying the treatment of non-security crypto assets under federal law.
What Changed
- The CFTC FAQs address implementation questions arising from two prior staff positions:
- Tokenized Collateral Guidance (CFTC Staff Letter 25-39): Established the framework allowing futures commission merchants (FCMs) and designated contract markets (DCMs) to accept digital assets as...
- No-Action Position (CFTC Staff Letter 26-05): Provided temporary relief permitting FCMs to accept payment stablecoins, Bitcoin, and Ether as customer margin collateral, subject to specific...
- How registered entities should operationalize tokenized collateral acceptance
- Compliance with notification and operational risk management requirements
Suggested Considerations
- *Immediate (0–30 days):
- *Asset Classification Audit: Map every crypto asset in your portfolios, products, or platforms against the five-category framework (digital commodities, digital collectibles, digital tools, stablecoins, digital securities) established in the March 17 joint interpretation.
- *Investment Contract Review: Identify any assets subject to active issuer promises of essential managerial effort—those remain securities regardless of category and cannot be treated as digital commodities.
- *FAQ Implementation Review: Obtain and review the full CFTC FAQs (available at https://www.cftc.gov/PressRoom/PressReleases/9200-26) to identify specific operational questions relevant to your entity type.
- *Notification Protocol Establishment: If relying on the no-action relief for tokenized collateral, establish procedures to notify the CFTC of significant operational, system, or cybersecurity issues affecting digital asset collateral use (required for first three months of relief).
Key Dates
SEC-CFTC Joint Interpretation Effective; The foundational joint interpretation establishing crypto asset taxonomy and digital commodity classification became effective upon Federal Register publication
FAQs Published; CFTC Market Participants Division and Division of Clearing and Risk issue clarifying FAQs effective immediately
GENIUS Act Stablecoin Exclusion; Final implementing rules for payment stablecoins issued by permitted issuers; interim staff position applies now
Disclosure & Program Updates; Firms must revise Form ADV, disclosure documents, offering materials, and custodial arrangements to reflect the new regulatory framework
Compliance Review Required; Asset classification audits, staking arrangement reviews, and investment contract assessments must begin now; enforcement posture is live
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Crypto ExchangeBroker DealerFintech
No description available.
Broker DealerAll Firms
Information Notice 3/17/26
This FINRA Information Notice announces an SEC-mandated increase in the Section 31 fee rate from $0.00 to $20.60 per million dollars of specified securities transactions, effective April 4, 2026, reversing a prior zero-rate period. It matters because FINRA member firms will face renewed fee assessments on exchange and OTC trades, requiring immediate systems updates and budgeting adjustments ahead of the short implementation timeline. https://www.finra.org/rules-guidance/notices/information-notice-20260317[original notice]
What Changed
- - Section 31 Fee Rate Increase: The rate for specified securities transactions on exchanges and OTC markets rises from $0.00 to $20.60 per million dollars in transactions, based on trade date (not...
- Security Futures Unchanged: The assessment remains at $0.0042 per round turn transaction.[original notice]
- FINRA Collection Mechanism: Fees are collected from member firms per Section 3 of Schedule A to FINRA By-Laws, aligned with SEC adjustments under Section 31 of the Exchange Act, following SEC...
- This follows a prior decrease to $0.00 effective May 14, 2025 (from $27.80), showing annual volatility in rates.
Suggested Considerations
- Systems/Processes Update: Adjust billing, trading, and reporting systems to apply the new rate to transactions with trade dates ≥ April 4, 2026; confirm "charge date" uses trade date per 17 CFR 240.31(a)(3).[original notice]
- Budgeting/Financial Planning: Forecast and reserve for fee liabilities based on projected transaction volumes; contact Amanda Rath for finance queries.[original notice]
- Legal Review: Consult Robert McNamee or Faisal Sheikh for interpretive questions; review By-Laws Schedule A Section 3.[original notice]
- Customer Disclosure: If passing fees to clients, ensure compliant disclosures (as reminded in prior notices).
- Monitor SEC: Check SEC website for further notices on rates.[original notice]
Key Dates
- SEC Fee Rate Advisory #2 for FY 2026 announced, setting new rate.[original notice]
- FINRA Information Notice published.[original notice]
- Effective date; new $20.60 rate applies to trades with charge date (trade date) on or after this date. Current $0.00 rate applies through April 3, 2026.[original notice]
Compliance Impact
Urgency: High - With only ~2.5 weeks from publication (March 17) to effective date (April 4, 2026), firms risk non-compliance, underbilling, or financial shortfalls if systems aren't updated promptly. This is critical for high-volume traders, as fees scale with transaction dollars, potentially adding significant costs post-zero-rate period; missing the trade-date trigger could lead to disputes or penalties. Historical patterns show frequent adjustments (e.g., 2025 drop to $0.00), demanding agile compliance processes.
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerBankAsset Manager
No description available.
BankFintechCrypto Exchange
The Securities and Exchange Commission’s Division of Economic and Risk Analysis (DERA) published a new report on security based swap dealers (SBSDs) and updated statistics and data visualizations on initial public offerings (IPOs), follow-on registered…
Broker DealerAsset Manager
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerAsset ManagerAll Firms
The Securities and Exchange Commission today proposed amendments to Exchange Act Rule 15c2-11, which sets out certain information gathering and review requirements for broker-dealers that publish quotations for, or maintain a continuous quoted market in…
The SEC is proposing amendments to Exchange Act Rule 15c2-11, which governs broker-dealer quotation requirements in OTC markets outside national securities exchanges, aiming to update information review standards for enhanced investor protection. This matters for compliance professionals as it could impose stricter due diligence on broker-dealers quoting OTC securities, building on 2020 amendments amid ongoing fixed income implementation challenges, potentially reducing fraud in retail-heavy OTC markets. https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
What Changed
Rule 15c2-11 requires broker-dealers to review current, publicly available issuer information (e.g., via EDGAR or issuer websites) before publishing or submitting quotations for OTC securities, with exceptions like piggybacking limited to scenarios with one-way priced quotes, post-trading suspension restrictions (60 days), and time-bound quoting for shell companies (18 months).
Suggested Considerations
- Review processes: Broker-dealers must verify current issuer info (financials for last 2 years, filings) is publicly available (EDGAR/website) before quoting; annual checks for Phase 3 fixed income.
- Exception compliance: Limit piggyback to priced quotes, avoid 60-day post-suspension, cap shell quoting at 18 months.
- Systems updates: Implement OTC quote surveillance for fixed income/private securities; document reviews.
- Issuer coordination: OTC issuers ensure info on EDGAR/website; monitor no-action phases.
- Comment submission: Firms respond to proposal via SEC portal during consultation.
Key Dates
Federal Register publication) - Proposed comment period closes; SEC seeks input on amendments.; (Inferred from "consultation" type; exact date not in summary.) https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
Compliance Impact
Urgency: High – Builds on enforced 2020/2021 changes with fixed income phases expired (Phase 3 active since 2024), pressuring broker-dealers on ongoing quotes amid SEC scrutiny; proposals could tighten "publicly available" standards or exceptions, risking enforcement for non-compliant OTC activity in fraud-prone markets. Matters as OTC is retail-dominated, amplifying gatekeeper liability; operational overhauls needed now to avoid quoting halts.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAll Firms
The Securities and Exchange Commission today announced that Judge Margaret A. Ryan has resigned from her role as Director of the Division of Enforcement. Principal Deputy Director Sam Waldon has been named Acting Director of the Division, effective March…
Judge Margaret A. Ryan, who assumed the role of SEC Enforcement Division Director in August 2025 and signaled a significant recalibration of enforcement priorities toward fraud and market integrity while reducing enforcement actions for technical violations, has resigned from the agency. Principal Deputy Director Sam Waldon has been named Acting Director, creating immediate uncertainty regarding continuity of the enforcement approach that was just articulated in February 2026 and may signal a shift in the SEC's enforcement trajectory going forward.
What Changed
- The resignation itself does not constitute a regulatory change, but it creates operational uncertainty regarding the enforcement priorities and procedural reforms that Director Ryan had recently...
- Reduced enforcement for technical violations: Director Ryan had signaled that routine violations concerning reporting requirements, recordkeeping, and internal accounting controls should not...
- "Middle ground" approach: For non-fraud violations posing investor or market integrity risks, the Division was to pursue resolutions emphasizing remediation over punishment.
- Continued fraud focus: The Division was to maintain rigorous enforcement on fraud, insider trading, market manipulation, and scams targeting retail investors.
Enforcement Manual Updates (Effective...
- Four-week timeline for post-Wells meetings with senior leadership (Associate Director level or above)
Suggested Considerations
- *Immediate (Next 30 Days):
- *Monitor Acting Director's statements: Compliance teams should closely track any public remarks or guidance from Acting Director Sam Waldon regarding enforcement priorities and procedural expectations.
- *Assess Wells submissions in progress: For entities with pending Wells submissions, evaluate whether the change in leadership creates opportunities to supplement submissions or request expedited meetings under the four-week timeline.
- *Review investigation status: Entities in early-stage investigations should assess whether the leadership transition may affect investigation trajectory or resolution opportunities.
- *Update compliance calendars: Ensure all enforcement-related deadlines and procedural requirements under the updated Enforcement Manual remain tracked and current.
Key Dates
- Director Ryan delivered public remarks outlining enforcement priorities and Wells process commitments
- SEC announced comprehensive updates to Enforcement Manual (first update since 2017)
- Judge Margaret A. Ryan's resignation announced; Sam Waldon named Acting Director (effective immediately)
- Four-week timeline for post-Wells meetings with senior leadership remains in effect pending Acting Director's confirmation of policy continuity
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAsset ManagerBank No description available.
BankBroker DealerAll Firms
No description available.
The CFTC secured a default judgment on March 13, 2026, against New York-based Safety Capital Management Inc. and GNS Capital Inc. (d/b/a ForexnPower) for retail forex fraud, fraud as commodity pool operators (CPOs) and commodity trading advisors (CTAs), and related violations of the Commodity Exchange Act (CEA), ordering over $2.4 million in restitution and penalties. This enforcement action underscores the CFTC's aggressive pursuit of fraud targeting vulnerable retail investors, with permanent injunctions against future violations, serving as a stark reminder for firms in forex, CPO, and CTA spaces to prioritize robust compliance programs.
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 in retail forex transactions (CEA Section 6(c)(1) and Regulation 180.1), CPO/CTA fraud, and related violations, with penalties triple the monetary gain and permanent injunctions. The judgment highlights judicial emphasis on exploiting vulnerable communities, such as non-English-speaking groups reliant on advisors.
Suggested Considerations
- Conduct gap analyses of retail forex, CPO, and CTA operations for fraud risks, especially in customer communications and targeting vulnerable groups.
- Enhance disclosures, suitability assessments, and recordkeeping to demonstrate non-reliance exploitation.
- Review parallel criminal risks (e.g., wire fraud, money laundering) and coordinate with counsel for SEC/DOJ exposure.
- Implement training on CEA Sections 4k, 4m, 4n, and Regulations 5.2-5.18 for retail forex; ensure CPO/CTA exemptions are valid.
- Monitor for restitution collection, noting CFTC caution on defendant insolvency.
Key Dates
- CFTC files original complaint against defendants
- Parallel criminal case filed (United States v. Kang, et al., No. 18-cr-184, E.D.N.Y.)
- Consent order resolves claims against Tae Hung Kang
- Summary judgment resolves claims against John H. Won
- U.S. District Court for the Eastern District of New York enters default judgment against Safety Capital and GNS, ordering payments and injunctions
Compliance Impact
Urgency: Medium - This resolves a decade-long case but reinforces CFTC's fraud enforcement focus, particularly on retail forex and vulnerable investors; firms should audit operations promptly to avoid similar defaults, as penalties (triple gains) and injunctions are severe, though not indicative of imminent rulemaking.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Asset ManagerBroker Dealer
No description available.
Broker DealerCrypto Exchange
No description available.
The CFTC has issued an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public comments on potential amendments or new regulations for event contracts in prediction markets, focusing on statutory compliance, public interest prohibitions, and cost-benefit analysis. This matters for compliance professionals as it signals heightened CFTC scrutiny and forthcoming rules that could reshape prediction market operations, amid jurisdictional disputes and enforcement priorities. (https://www.cftc.gov/PressRoom/PressReleases/9194-26)
What Changed
- This ANPRM proposes no immediate changes, as it is an early-stage consultation seeking input on:
- Application of Commodity Exchange Act (CEA) core principles and existing CFTC regulations to prediction markets.
- Criteria for prohibiting event contracts deemed contrary to the public interest (e.g., potentially sports, politics, or sensitive topics like government employee outcomes).
- Cost-benefit analyses for regulating prediction markets.
It builds on prior actions, including withdrawal of a 2024 proposed ban on certain event contracts and a 2025 staff advisory on sports-related...
Suggested Considerations
- Submit comments: Affected parties should prepare and file written comments within 45 days via the CFTC Public Comments Portal, addressing ANPRM questions on CEA principles, prohibited contracts, and costs/benefits.
- Monitor developments: Track Federal Register publication, related litigation (e.g., state challenges to CFTC jurisdiction), and CFTC Enforcement Division advisories. (https://www.cftc.gov/PressRoom/PressReleases/9183-26)
Key Dates
- Deadline for public comments (45 days after Federal Register publication; ANPRM published March 12, 2026). Comments via CFTC Public Comments Portal. (https://www.cftc.gov/PressRoom/PressReleases/9194-26)
Compliance Impact
Urgency: High - This ANPRM initiates rulemaking that could prohibit certain event contracts or impose new CEA compliance burdens, amid CFTC Enforcement Division advisories on misconduct (e.g., MNPI, manipulation) and jurisdictional defenses against states/SEC. Firms risk enforcement actions if unprepared, especially as prediction markets grow with institutional interest; proactive commenting and program reviews are essential to influence outcomes and mitigate risks.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerCrypto ExchangeAll Firms
No description available.
Broker DealerCrypto ExchangeAll Firms
The two agencies have entered into a MOU to guide coordination and collaboration to support lawful innovation, uphold market integrity, and ensure investor and customer protection.
Broker DealerCrypto Exchange
No description available.
Broker DealerFintechCrypto Exchange
No description available.
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerAsset Manager
No description available.
Broker DealerCrypto Exchange
The Securities and Exchange Commission’s Investor Advisory Committee will hold a public meeting at the SEC Headquarters in Washington D.C. on March 12 at 10 a.m. ET to discuss public company disclosure reform, fund proxy voting, and a potential…
Asset ManagerBroker DealerWealth Manager
The Securities and Exchange Commission announced today that it will host a roundtable on April 16, 2026, to discuss listed options market structure, including facilitating competition in a quote driven market, evaluating the customer experience, and…
Broker DealerAll Firms
Regulatory Notice 26-05
Broker DealerWealth ManagerBank
No description available.
Broker DealerBank
No description available.
No description available.
The CFTC announced on March 2, 2026, the appointment of David I. Miller, a former federal prosecutor and white-collar defense attorney, as Director of Enforcement, replacing acting director Paul Hayeck. This leadership change signals a potential shift toward stricter enforcement against fraud, market manipulation, and abusive trading practices, particularly in commodities and digital assets, while emphasizing the division's core policing role over policy-making. Compliance professionals should monitor this for evolving enforcement priorities, as Miller's prosecutorial background and digital asset experience may intensify scrutiny on high-risk activities.
What Changed
This announcement introduces no new regulatory rules, requirements, or statutory changes; it is a personnel appointment reshaping enforcement leadership. Chairman Selig highlighted Miller's role in refocusing the Enforcement Division on "policing fraud, abuse, and manipulation rather than setting policy," potentially signaling reduced pursuit of novel legal theories and a narrower enforcement scope.
Suggested Considerations
- Review internal controls for fraud, manipulation, and abusive trading, prioritizing digital asset activities (e.g., derivatives, prediction markets).
- Assess exposure from Miller's past cases (e.g., BitMEX, ICOs, Ooki DAO) and strengthen defenses against similar enforcement theories.
- Monitor CFTC enforcement dockets and coordinate with counsel experienced in CFTC/SEC/DOJ matters for upcoming investigations.
- Update training on "core" violations (fraud, abuse, manipulation) to align with stated enforcement focus.
Key Dates
Paul Hayeck began as acting director; (historical context; Hayeck transitions to Complex Fraud Task Force chief)
Announcement and effective start of David I. Miller as Director of Enforcement
Compliance Impact
Urgency: Medium. This matters because the new Director influences case selection, resource allocation, and prosecutorial priorities, potentially increasing enforcement momentum in commodities and crypto amid CFTC's staffing buildup and jurisdictional expansions. Firms with digital asset exposure face heightened risk of investigations into fraud/manipulation, but the "narrower" focus may reduce pursuits of expansive theories, offering predictability for compliant actors. Track for 3-6 months to observe initial actions.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerCrypto ExchangeAll Firms
The Securities and Exchange Commission today adopted final rule and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable Act (HFIA), which will increase transparency into the holdings and transactions…
The SEC adopted final rules on February 27, 2026, implementing the Holding Foreign Insiders Accountable Act (HFIA), which extends Section 16(a) beneficial ownership reporting requirements to directors and officers of foreign private issuers (FPIs) with Exchange Act Section 12-registered equity securities, effective March 18, 2026. This aligns FPI insiders' disclosure obligations with those of U.S. domestic issuers, enhancing market transparency while exempting >10% holders from reporting. Compliance professionals must prioritize preparation as the deadline approaches in two weeks from today (March 3, 2026).
What Changed
- - Extension of Section 16(a) Reporting: Directors and officers of FPIs must now file Forms 3 (initial beneficial ownership), 4 (changes in ownership), and 5 (annual summary) electronically and in...
- Rule Amendments:
- Rule 3a12-3(b): Removes full Section 16 exemption for FPI insiders; retains exemptions only for Section 16(b) short-swing profits and Section 16(c) short-selling prohibitions....
- Form Updates: Forms 3, 4, and 5 amended to include non-U.S. issuers and reporters; technical changes to instructions for EDGAR support contacts and paper filing addresses.
- Exemptive Authority: SEC may exempt persons/securities/transactions if foreign laws impose "substantially similar" requirements, but no exemptions granted yet; staff evaluating.
Suggested Considerations
- For FPIs and Insiders: Identify all directors/officers subject to Section 16; implement processes for electronic/English-language filings via EDGAR; file initial Form 3 by March 18, 2026 (or sooner for new appointees); establish transaction monitoring for prompt Form 4 filings.
- Training and Policies: Update insider trading policies, provide training on forms/reporting timelines; designate EDGAR filers with proper contacts.
- Systems Preparation: Integrate with trading/brokerage systems for real-time ownership tracking; prepare for Form 5 annual reconciliations.
- Monitor Exemptions: Watch for SEC exemptive relief based on foreign law equivalency; assume compliance required absent announcement.
Key Dates
HFIA enacted into law
SEC adopts final rules (ahead of 90-day mandate)
Effective date; directors/officers of existing FPIs must file initial Form 3; new directors/officers file within 10 days of appointment; ongoing Forms 4 within 2 business days of transactions
Annual Form 5 for unreported transactions; adopting release published in Federal Register (date TBD)
Compliance Impact
Urgency: Critical – With the March 18, 2026, effective date just two weeks away (as of March 3, 2026), non-compliance risks SEC enforcement, including public disclosure failures and potential civil penalties under Section 16. This materially heightens governance burdens for FPIs, demands immediate system/process overhauls, and aligns foreign insiders with U.S. standards to prevent opacity in cross-border listings.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
All Firms
The U.S. Securities and Exchange Commission (SEC) and the Financial Services Agency of Japan (FSA) convened the Spring SEC-FSA Financial Regulatory Dialogue in Tokyo on Feb. 27, 2026.The SEC–FSA Dialogue builds upon longstanding efforts between the two…
BankAsset ManagerBroker Dealer
No description available.
Asset ManagerHedge Fund
The Securities and Exchange Commission today announced it will hold a roundtable on March 4 to discuss private market valuations and responsible retailization.The roundtable will be hosted by the Division of Investment Management from 1 p.m. to 3 p.m. ET…
Asset ManagerBroker DealerFintech No description available.
The CFTC Enforcement Division issued an advisory on February 25, 2026, detailing two enforcement cases involving illegal trading on prediction markets (event contracts) traded on KalshiEX, a Designated Contract Market. The advisory clarifies that the CFTC maintains full enforcement authority over prediction markets and will prosecute violations including insider trading, market manipulation, and fraud—establishing critical compliance expectations for platforms and traders in this emerging asset class.
What Changed
- The advisory does not introduce new rules but rather reaffirms existing CFTC enforcement authority over prediction markets and clarifies the scope of prohibited conduct:
- Insider trading/misappropriation: Trading based on material nonpublic information obtained through a breach of fiduciary duty or pre-existing duty of trust and confidence (Section 6(c)(1) of the...
- Fraud and manipulation: Use of manipulative schemes or artifices to defraud, including trading in contracts where the trader has direct or indirect influence over the outcome
- Pre-arranged and wash trades: Noncompetitive trading under Section 4c(a)(1) and (2)(A) and Regulation 1.38(a)
- Disruptive trading practices: Violations under Section 4c(a)(5)
The advisory demonstrates the CFTC's commitment to enforce these prohibitions on prediction market platforms, reinforcing that...
Suggested Considerations
- *For Prediction Market Platforms (DCMs):
- *Implement robust surveillance systems to detect trading by individuals with material nonpublic information or direct/indirect influence over contract outcomes
- *Establish clear trading prohibitions in exchange rules addressing:
- Trading in contracts where the trader has influence over the outcome
- Trading based on material nonpublic information obtained through breach of duty
Key Dates
- First enforcement case (political candidate trading incident) identified and resolved by Kalshi
- CFTC Enforcement Division issues Prediction Markets Advisory
September 2025; - Second enforcement case (YouTube editor trading incident) identified and resolved by Kalshi
- Advisory does not establish new compliance deadlines; it clarifies existing obligations
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Crypto ExchangeBroker Dealer
The Securities and Exchange Commission’s Division of Enforcement today announced significant updates to its Enforcement Manual. These updates underscore the Commission’s ongoing commitment to fairness, transparency, and efficiency in the investigations…
The SEC's Division of Enforcement announced updates to its Enforcement Manual on February 24, 2026, focusing on enhancing fairness, transparency, and efficiency in investigations through standardized procedures like the Wells process and settlement considerations. These changes, the first major revisions since 2017, introduce uniform timelines and best practices to streamline resolutions and improve dialogue with investigated parties. Compliance professionals should prioritize this as it directly affects how firms respond to SEC inquiries, potentially accelerating outcomes and reducing uncertainties in enforcement actions.
What Changed
- The updates target investigative and enforcement procedures for greater consistency:
- Uniform Wells process: Recipients of a Wells notice receive four weeks to submit responses; Wells meetings are scheduled within four weeks of submission and include senior Division leadership.
- Simultaneous settlement and waiver consideration: Restores practice allowing settling parties to request Commission waivers from collateral consequences (e.g., disqualifications) alongside settlement...
- Additional enhancements: Details framework for evaluating cooperation (including civil penalty impacts); promotes internal collaboration; updates formal order processes, criminal referrals, and...
Suggested Considerations
- Review the updated Enforcement Manual (https://www.sec.gov/files/enforcementmanual.pdf) and train compliance/in-house legal teams on new Wells timelines and submission guidance.
- Update internal policies for responding to Wells notices: Prepare submissions within four weeks, focusing on elements staff find "most helpful" (e.g., detailed facts, legal analysis).
- For settlements, incorporate simultaneous waiver requests in offers to leverage restored process and mitigate collateral impacts.
- Enhance cooperation strategies per new evaluation framework to potentially reduce civil penalties; document internal collaboration for enforcement interactions.
- Monitor annual Manual reviews via SEC Division of Enforcement page (https://www.sec.gov/about/divisions-offices/division-enforcement).
Key Dates
- Updates to Enforcement Manual announced and effective; last major revision was 2017, with annual reviews planned going forward
- Standard deadline for Wells submissions
- Scheduling of Wells meetings with senior leadership
Compliance Impact
Urgency: High - These procedural updates are immediately effective and alter critical interaction points with SEC staff, such as Wells responses and settlements, which can determine investigation closure, enforcement recommendations, or penalty severity. Firms under active scrutiny or anticipating inquiries gain from predictable timelines reducing prolonged uncertainty, but must adapt quickly to avoid suboptimal outcomes; non-compliance risks inefficient resolutions or missed cooperation credits.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerHedge Fund No description available.
BankFintechCrypto Exchange
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerAll Firms
No description available.
Asset ManagerBroker DealerWealth Manager
No description available.
Broker DealerCrypto Exchange
No description available.
Crypto ExchangeAll Firms
The Securities and Exchange Commission will host the agency’s 45th Annual Government Business Forum on Small Business Capital Formation at SEC headquarters in Washington, D.C., on March 9 from 1 p.m. to 5 p.m. ET. The event will be webcast live. …
Asset ManagerBroker DealerFintech
No description available.
Crypto ExchangeFintech
The Securities and Exchange Commission’s Division of Economic and Risk Analysis (DERA) has published two new reports on exchange traded funds and fund mergers, and updated statistics and data visualizations on municipal advisors, transfer agents, and…
Asset ManagerBroker Dealer
No description available.
The CFTC has withdrawn its 2024 proposed rulemaking on "Event Contracts" (which sought to prohibit political event contracts) and the 2025 Staff Advisory (No. 25-36) on sports event contracts, signaling a policy shift under new Chairman Michael S. Selig toward promoting innovation via new rulemaking. This matters because it removes prior restrictive guidance, reduces immediate compliance burdens on prediction market operators, and opens the door for lawful event contracts while hinting at CFTC asserting exclusive jurisdiction over these derivatives.
What Changed
- - Withdrawal of the June 10, 2024, Notice of Proposed Rulemaking titled “Event Contracts,” which proposed prohibiting political event contracts as contrary to public interest (e.g., akin to war or...
- Withdrawal of CFTC Staff Letter 25-36 (issued Sept. 30, 2025), a Staff Advisory cautioning designated contract markets (DCMs) against offering sports event contracts due to litigation risks and state...
- Commitment to new event contracts rulemaking based on a "rational and coherent interpretation of the Commodity Exchange Act" to promote innovation, with clear standards for prediction markets; CFTC...
Suggested Considerations
- Review and disregard prior compliance programs built around the 2024 proposal or 2025 advisory (e.g., cease preparations for prohibiting political/sports contracts).
- Monitor CFTC docket for new event contracts rulemaking notice and provide comments during any future consultation period.
- Assess current offerings for event contracts under existing Commodity Exchange Act prohibitions (e.g., gaming, manipulation); document reliance on CFTC's innovation stance pending new rules.
- Evaluate litigation exposure, especially state gaming regulator actions; prepare for potential CFTC intervention asserting exclusive jurisdiction.
- No immediate prohibitions lifted or mandates imposed—continue operating within current CEA framework (e.g., anti-fraud, market integrity).
Key Dates
- Publication of withdrawn "Event Contracts" Notice of Proposed Rulemaking
- Issuance of withdrawn CFTC Staff Letter 25-36 (Sports Event Contracts Advisory)
- CFTC announcement withdrawing both the 2024 proposal and 2025 advisory; no final rules from 2024 proposal; new rulemaking to advance
Compliance Impact
Urgency: Medium – This withdrawal immediately eliminates overhang from restrictive proposals/advisories, allowing firms to pivot from prohibition compliance to innovation planning without urgent deadlines. It matters for reducing uncertainty in prediction markets but requires vigilance for new rules, jurisdictional fights, and insider trading clarity, as platforms like Polymarket face ongoing scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerFintechCrypto Exchange
No description available.
BankBroker DealerHedge Fund
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Broker DealerFintech
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BankBroker Dealer
The Securities and Exchange Commission today announced the appointment of Demetrios (Jim) Logothetis, as Chairman, and Mark Calabria, Kyle Hauptman, and Steven Laughton, as Board members, of the Public Company Accounting Oversight Board (PCAOB). George…
Asset ManagerBroker DealerBank
No description available.
Crypto ExchangeFintechAll Firms
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Crypto ExchangeFintech
No description available.
Crypto ExchangeFintechAll Firms
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All Firms
The Securities and Exchange Commission today filed settled charges against Archer-Daniels-Midland Company (ADM) and its former executives, Vince Macciocchi and Ray Young, and a litigated action against its former executive Vikram Luthar, for …
Broker DealerAsset Manager
No description available.
Broker Dealer
No description available.
Broker DealerFintechCrypto Exchange
No description available.
Crypto ExchangeFintech
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event, previously scheduled for Jan. 27, now rescheduled for Thursday, Jan. 29, from 2 p.m. to 3 p.m. at CFTC…
Crypto ExchangeFintech
Equity-Indexed Annuities
Broker DealerWealth ManagerAsset Manager
Engagement
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Enforcement Process
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Enforcement
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Electronic Fingerprint Processing
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Electronic Communications
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Direct Participation Programs (DPPs)
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Digital Experience Transformation (DXT)
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Derivatives and Other Balance Sheet Items (OBS)
Broker DealerAsset ManagerBank
Derivatives
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Department of Labor
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Deferred Annuities
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Day Trading
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Cybersecurity
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Customer Orders
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Customer Information Protection
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Customer Account Transfers
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Customer Account Statements
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Crypto Assets
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Credit for Cooperation
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COVID-19 / Coronavirus
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Correspondence
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Corporate Financing
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Corporate Bonds
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Continuing Education
Broker DealerWealth ManagerAsset Manager Consolidated Reports
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Consolidated Audit Trail (CAT)
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Conflicts of Interest
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Comprehensive Automated Risk Data System (CARDS)
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Compensation
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Communications with the Public
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Central Registration Depository (CRD)
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Carrying Agreements
Broker DealerAsset ManagerBank
Capital Formation
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Capital Acquisition Brokers
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Business Continuity Planning
Broker DealerBankAsset Manager
BrokerCheck
Broker DealerWealth ManagerAll Firms
Broker-Dealer Recruitment Disclosures
Broker DealerWealth ManagerAll Firms
Books and Records
Broker DealerAsset ManagerBank
Bond Mutual Fund Volatility/Risk Rating
Asset ManagerBroker Dealer
Blue Sheets
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Block Chain / Distributed Ledger Technology
Broker DealerFintechCrypto Exchange
Best Practices
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Best Execution
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Auction Rate Securities
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Asset Backed Securities
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Artificial Intelligence
Broker DealerAsset ManagerBank Arbitration and Mediation
Broker DealerWealth ManagerBank Anti-Money Laundering
Broker DealerBankAsset Manager
Annual Audit
Broker DealerAsset ManagerBank
Alternative Display Facility (ADF)
Broker DealerAsset ManagerBank
Alternative and Complex Products
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Algorithmic Trading
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Agency Bonds
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Advertising Regulation
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Regulatory Notice 25-01
Broker DealerBank
Information Notice - 1/3/25
FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
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 processing timeframes remained unaffected by the market closure.
- Restricted Exercise Classes: Exercises in non-expiring American-style, cash-settled index options and non-expiring American-style, cash-settled FLEX ETF option classes were prohibited on January 9,...
Suggested Considerations
- *Update Internal Procedures: Modify systems and workflows to enforce the 10:00 a.m. ET cut-off instead of the standard 5:30 p.m. ET deadline for January 9, 2025 options
- *System Configuration: Reprogram trading platforms, order management systems, and compliance monitoring tools to reject exercise instructions received after 10:00 a.m. ET on that date
- *Staff Communication: Notify all relevant personnel (trading desk, operations, compliance, customer service) of the accelerated deadline and restricted exercise classes
- *Customer Notification: Inform retail and institutional clients of the early cut-off time for options expiring on January 9, 2025
- *Submission Coordination: Ensure CEA submissions to exchanges and OCC occur within the compressed timeframe
Key Dates
10:00 a.m. ET; Final deadline for option holders to make exercise/non-exercise decisions and for members to accept exercise instructions (accelerated from standard 5:30 p.m. ET)
10:00 a.m. ET; Final deadline for members to submit Contrary Exercise Advice to exchanges or OCC (accelerated from standard 5:30 p.m. ET or 7:30 p.m. ET depending on account type and submission method)
National Day of Mourning; national options exchanges closed; exercises in specified option classes prohibited
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker DealerAll Firms
Regulatory Notice 25-02
Broker DealerBankAsset Manager
Regulatory Notice 25-03
Broker DealerBankAsset Manager
Regulatory Notice 25-04
Broker DealerWealth ManagerFintech Regulatory Notice 25-05
Broker DealerWealth ManagerAsset Manager
Regulatory Notice 25-06
Broker DealerAsset Manager
Regulatory Notice 25-07
Broker DealerAsset ManagerFintech
Information Notice - 4/24/25
This FINRA Information Notice announces the SEC's reduction of the Section 31 fee rate to $0.00 per million dollars in specified securities transactions, effective May 14, 2025, following the SEC's Fee Rate Advisory for Fiscal Year 2025. It matters because it eliminates these transaction fees for FINRA member firms for the remainder of FY 2025 (and potentially beyond until FY 2026 appropriations), reducing costs and simplifying billing processes amid the SEC's over-collection of its appropriation target.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
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...
- 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 will assess fees on member firms per Section 3 of Schedule A to the By-Laws, aligned with SEC adjustments made in consultation with the Congressional Budget Office and Office of Management and...
Suggested Considerations
- Update internal billing, invoicing, and financial reporting systems to reflect the $0.00 rate starting May 14, 2025, using trade date as the charge date per 17 CFR 240.31(a)(3).[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
- 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.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
- Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date.
Key Dates
- SEC announces Fee Rate Advisory for Fiscal Year 2025
- FINRA publishes Information Notice.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
- Last day for current rate of $27.80 per million (trade dates through this date).[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
- New rate of $0.00 per million takes effect for trade dates (charge dates) on or after this date; applies to OTC sales and options settlements/exercises.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
- $0.00 rate remains in effect
Compliance Impact
Urgency: Low - This is a beneficial change eliminating fees due to SEC over-collection, with no new requirements or penalties; firms already past the May 14, 2025, effective date (as of January 2026) face minimal risk if systems were updated timely. It matters for cost savings, accurate financials, and avoiding erroneous collections, but non-compliance (e.g., continued billing) could lead to refunds or disputes rather than enforcement.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Special Notice – 5/15/25
Broker DealerAsset ManagerAll Firms
Information Notice - 6/26/25
This FINRA Information Notice announces the termination of **Prospective CAT Cost Recovery Fee 2025-1** effective July 1, 2025, with **Prospective CAT Cost Recovery Fee 2025-2** taking effect for transactions in eligible securities by FINRA member CAT executing brokers. It matters because firms must transition billing and payment processes seamlessly to avoid disruptions in CAT cost recovery compliance under FINRA Rule 6897(b)(1)(D).
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).
Suggested Considerations
- 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
- Last day Prospective CAT Cost Recovery Fee 2025-1 applies to transactions
- Prospective CAT Cost Recovery Fee 2025-2 takes effect for transactions
- Last invoice sent for Fee 2025-1 (based on June 2025 transactions)
- Payments due for Fee 2025-1 final invoice; first invoices for Fee 2025-2 issued (based on July transactions)
Compliance Impact
Urgency: Medium - Primarily administrative; no new reporting burdens, but failure to transition could lead to underpayment, late fees, or Rule 6897 violations. Matters for high-volume brokers due to monthly cash flow impacts and ongoing CAT funding obligations (totaling FINRA's 2025 budgeted costs). As of January 2026, firms should have adapted, but audits may flag non-compliance.
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Regulatory Notice 25-08
Broker DealerAsset Manager
Information Notice - 8/14/25
This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
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...
- 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...
- 2025 Regulatory Element courses are pre-assigned via FinPro Gateway, with topics viewable via FINRA's interactive tool; changes occur if registrations are...
Suggested Considerations
- Registered persons: Log into FinPro Gateway to complete assigned 2025 Regulatory Element courses by deadline (or request extension via firm for good cause); update contact info for notifications.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
- Firms: Conduct annual Firm Element needs analysis and develop written training plans using FLEX and published Regulatory topics; monitor completion, request extensions if needed, and maintain records.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
- Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Key Dates
- FINRA publishes upcoming Regulatory Element topics by registration category
- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Compliance Impact
Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liability for inadequate monitoring, with repeated reminders (e.g., 2024 notice) signaling FINRA enforcement focus.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker DealerAll Firms
Election Notice – 9/4/25
Broker DealerAsset ManagerBank
Regulatory Notice 25-10
Broker DealerBankFintech
Regulatory Notice 25-11
Broker DealerBankAsset Manager
Regulatory Notice 25-12
Broker DealerBank
Election Notice – 10/20/25
Broker DealerAsset ManagerAll Firms
Information Notice - 10/21/25
FINRA's Information Notice dated October 21, 2025, reminds member firms of NSCC's amendment to Rule 50, effective October 17, 2025, which removes the "Settle Prep Day" from the ACATS process, shortening full customer account transfers to 3-4 business days. This matters because it aligns with FINRA Rule 11870's requirements to expedite transfers, enhances operational efficiency, reduces risk, and improves client experience amid broader industry shifts like T+1 settlement.[original notice]
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...
- 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...
- Overall Timeline Reduction: Full ACATS transfers now complete in 3-4 business days (previously longer), supporting faster asset access without manual processes.
- FINRA Rule 11870 remains unchanged but continues to mandate use of ACATS (when both firms participate), prompt validation/exceptions, and coordination to expedite transfers.[original notice]
Suggested Considerations
- Operational Readiness: Coordinate between transfer and settlement operations to handle shortened cycles and next-day settling; validate/except instructions within 3 business days per FINRA Rule 11870(b).[original notice]
- Exception Handling: Promptly resolve any transfer instruction exceptions (Rule 11870(b)(2)); ensure ACATS data meets minimum requirements to avoid rejections.
- System Updates: Migrate to new ACATS interfaces/formats ahead of October 2026 decommission; test for mutual funds, options, and complex assets.
- Contact FINRA/NSCC: Direct questions to Kathryn Mahoney (FINRA) at (646) 315-8428 or email; reference NSCC Important Notice A9646 for details.[original notice]
- Monitoring: Firms should already be compliant as enhancement launched October 17, 2025; address any post-implementation issues via DTCC support.
Key Dates
- SEC approves NSCC's proposed rule change (File No. SR-NSCC-2025-011) amending Rule 50.[original notice]
- Federal Register publication of SEC approval (90 FR 43709).[original notice]
- Effective date: Removal of Settle Prep Day and Fund/SERV changes; firms must support next-day settling assets.[original notice]
- Planned modernization of ACATS client interfaces (decommission of legacy formats; migration to JSON/MQ for enhanced messaging)
Compliance Impact
Urgency: Medium - Effective over three months ago (as of January 2026), with industry-wide accommodation confirmed; no new mandates but requires ongoing operational alignment to avoid Rule 11870 violations (e.g., delays in validation or exceptions). Matters for reducing transfer failures, enhancing efficiency post-T+1, and minimizing client complaints on account mobility; non-compliance risks FINRA scrutiny on customer protection.[original notice]
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker DealerWealth ManagerAll Firms
Regulatory Notice 25-14
Broker DealerAsset Manager
Information Notice - 11/7/25
FINRA's Information Notice 11/7/25 publishes a **2026 Filing Schedule** on its website to guide clearing firms on accurate submission dates for extensions of time under Federal Reserve Regulation T, SEA Rule 15c3-3, and FINRA Rule 4210, accounting for holidays and business days. This matters because the automated REX system rejects incorrect dates, forcing resubmissions that delay compliance and risk regulatory violations amid shortened settlement cycles.
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).
Suggested Considerations
- Access and reference the 2026 Filing Schedule on FINRA's website (via https://www.finra.org/rules-guidance/notices/information-notice-20251107 or related pages) for all REX system submissions.
- 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
- Notice published; 2026 Filing Schedule made available on FINRA website
- Use Filing Schedule for all extension requests, especially pre/post-holidays (e.g., Veterans Day 11/11/2026 bank holiday, Thanksgiving 11/26/2026, Christmas 12/25/2026)
- (d)(2)
- (d)(3), (h)
- (d)(4)
Compliance Impact
Urgency: Medium - Proactive guidance prevents operational disruptions from REX rejections, but no immediate deadlines or penalties for non-use; however, inaccurate filings risk delayed margin compliance, customer liquidations under Regulation T, or possession/control failures under SEA Rule 15c3-3, especially in holiday periods with T+1 settlement pressures. Firms should integrate now (as of January 2026) to ensure Q1 readiness.
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Information Notice 11/10/25
FINRA Information Notice 11/10/25 provides due dates for 2026 and Q1 2027 filings of Annual Reports, FOCUS Reports, Form Custody, and various supplemental schedules under SEA Rule 17a-5 and FINRA Rule 4524. It matters because it ensures timely electronic submissions via FINRA Gateway, incorporates SEC amendments for EDGAR PDF filings (with future Interactive Data requirements), and highlights a 30-day extension option for qualifying smaller firms, helping prevent compliance failures amid federal holidays. https://www.finra.org/rules-guidance/notices/information-notice-20251110
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...
- 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)...
- 30-Day Extension for Annual Reports: Available under SEC February 2021 order for qualifying SIPC members (e.g., smaller firms facing audit burdens), requiring FINRA notification per Regulatory Notice...
- SIPC Filing via FINRA: SIPC members' Annual Report filings through FINRA Gateway satisfy SIPC requirements via agreement. https://www.finra.org/rules-guidance/notices/information-notice-20251110
Suggested Considerations
- Submit all filings electronically via FINRA Gateway by 11:59 p.m. ET on due dates; obtain EDGAR access for Annual Reports.
- For 30-day extension: Confirm eligibility per SEC order, notify FINRA as in Regulatory Notice 21-05 before standard due date. https://www.finra.org/rules-guidance/notices/information-notice-20251110
- Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable.
- Prepare for Interactive Data: Larger firms by mid-2027 (test EDGAR Interactive Data Files).
- Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site. https://www.finra.org/rules-guidance/notices/information-notice-20251110 https://www.finra.org/sites/default/files/2025-11/Information-Notice-20251110.pdf
Compliance Impact
Urgency: High – Multiple imminent deadlines (e.g., January 27-29, 2026 for Q4 2025 filings, just days from today), mandatory electronic/EDGAR shifts, and late fees/exam risks for misses; smaller firms gain extension relief but must notify promptly. Non-compliance risks enforcement under SEA Rule 17a-5, operational disruptions, and audit delays. https://www.finra.org/rules-guidance/notices/information-notice-20251110
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker DealerAll Firms
Regulatory Notice 25-15
Broker DealerBank
Information Notice 11/14/25
FINRA Information Notice 11/14/25 summarizes SEC amendments to SEA Rule 17a-5 mandating electronic filing of broker-dealer annual reports, supplemental reports, and Form 17-H on EDGAR in PDF format, alongside FOCUS Report updates including electronic signatures and elimination of notarization. These changes modernize submissions, eliminate paper filings to the SEC, and impose new interactive data requirements with phased compliance, requiring broker-dealers to secure EDGAR access and adapt processes promptly to avoid disruptions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
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...
- 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...
- Oath or Affirmation Updates: Notarization eliminated; signed version must be retained for at least 6 years (first 2 in easily accessible place) per SEA Rule...
- Interactive Data Files: Annual/supplemental reports and Form 17-H must be submitted as Interactive Data Files under Regulation S-T Rule 405, with phased compliance based on net capital.
- FINRA Submissions Unchanged: Annual reports to FINRA remain electronic via existing systems; FOCUS changes detailed on FINRA's eFOCUS...
Suggested Considerations
- Obtain EDGAR access credentials via Form ID if not previously filed (submit early via SEC's "Apply for EDGAR Access" instructions); contact EDGAR Filer Technical Support at (202) 551-8900 Option #3 for help.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
- Transition annual/supplemental reports and Form 17-H to EDGAR PDF submissions effective fiscal years ending on/after June 30, 2025; follow SEC's Electronic Filing of Form X-17A-5 Part III instructions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
- Implement electronic signature processes (e.g., Adobe digital certificates) for SEA Rule 17a-5 reports; limit FOCUS signatures to one principal officer.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
- Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
- Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance).
Key Dates
Electronic PDF filing on EDGAR mandatory for annual reports (fiscal years ending on/after this date), supplemental reports (SEA Rule 17a-5(k)), and Form 17-H; no paper accepted.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Reference date for determining firm net capital threshold ($250,000+) for interactive data compliance phasing
Interactive Data File requirement applies to filings due on/after for firms with ≥ $250,000 minimum net capital (as of 12/31/2025)
Interactive Data File requirement applies to filings due on/after for firms with < $250,000 minimum net capital (as of 12/31/2025)
due date; Submit Form ID for EDGAR access (5-7 business day approval delay).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Compliance Impact
Urgency: High – Immediate action needed for EDGAR access and PDF filings (past June 30, 2025 deadline as of January 2026), risking filing rejections or enforcement if unprepared; interactive data adds future burden but allows planning. Matters due to SEC's zero-tolerance for paper, potential delays in EDGAR approvals, and operational shifts in signing/retention, amplifying risks for non-compliant firms amid FINRA/SEC modernization push.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Information Notice 11/17/25
FINRA Information Notice 11/17/25 reminds member firms of a modified exercise cut-off time for standardized equity options expiring on November 28, 2025, due to national options exchanges closing early at 1:00 p.m. ET on the Friday after Thanksgiving. This adjustment shifts the deadline for option holders' final exercise decisions from 5:30 p.m. ET to 2:30 p.m. ET under FINRA Rule 2360(b)(23)(A)(viii). It matters for compliance as firms must enforce this deadline to avoid regulatory violations, protect client positions, and manage operational risks during a holiday-shortened trading day.
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...
- 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 (Exercise-by-Exception) unless a Contrary Exercise Advice is submitted (to override auto-exercise or exercise...
Suggested Considerations
- Update client communications: Notify option holders of the 2:30 p.m. ET deadline well in advance (e.g., via alerts, trade confirmations).
- Configure systems and procedures: Ensure trading platforms reject post-2:30 p.m. ET instructions; test auto-exercise and Contrary Exercise Advice processes.
- Train staff: Educate operations/trading personnel on Rule 2360(b)(23), OCC Rule 805, and holiday-specific cut-off; document training.
- Monitor and record: Log all exercise instructions, auto-exercises, and any Advice Cancels; retain for surveillance.
- Optional: Establish firm-internal earlier cut-offs (e.g., 2:00 p.m. ET) but enforce no later than 2:30 p.m. ET.
Key Dates
- Early close of national options exchanges
- Firm deadline to accept final exercise/not-exercise decisions (no later instructions permitted)
- Publication of FINRA Information Notice 11/17/25 reminding firms of upcoming modified cut-off
Compliance Impact
Urgency: low (post-event as of January 2026). This is a one-time reminder for a past holiday adjustment, with low risk of enforcement absent systemic failures. It matters operationally to prevent erroneous exercises, client disputes, or capital charges from uncollected exercise costs, but non-compliance could trigger FINRA surveillance reviews under Rule 2360. Firms should audit 2025 records now for lessons on future early-closes (e.g., Good Friday).
AI-generated analysis. May contain errors or omissions — verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Regulatory Notice 25-17
Broker DealerAsset ManagerBank
Regulatory Notice 25-19
Broker DealerAsset Manager
Regulatory Notice 26-01
Broker DealerAsset Manager
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerFintechAll Firms
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Crypto ExchangeFintech
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event on Tuesday, Jan. 27, from 10 a.m. to 11 a.m. at CFTC headquarters to discuss harmonization between the…
BankBroker DealerCrypto Exchange The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee announced that it will hold a public meeting at the SEC Headquarters in Washington, D.C., on Tuesday, Feb. 24, 2026, at 10 a.m. ET. The meeting will also be…
Broker DealerFintechCrypto Exchange
The Securities and Exchange Commission today approved the 2026 budget for the Public Company Accounting Oversight Board (PCAOB) and the related accounting support fee.The 2026 PCAOB budget totals $362.1 million. The 2026 budget reflects a 9.4% ($37.6…
Broker DealerBank
The Securities and Exchange Commission is seeking candidates for appointment as members of the SEC’s Investor Advisory Committee, established pursuant to Section 39 of the Securities Exchange Act of 1934 to help protect investors and improve securities…
Asset ManagerBroker DealerWealth Manager
The Securities and Exchange Commission is seeking candidates to fill a limited number of vacancies on the agency’s Small Business Capital Formation Advisory Committee, which provides advice and recommendations to the Commission on rules, regulations, and…
Broker DealerAsset ManagerAll Firms
The Securities and Exchange Commission today announced the senior team from the Division of Corporation Finance responsible for advising division Director James Moloney on all matters the division has before the Commission. These include rulemaking…
BankBroker DealerWealth Manager The Securities and Exchange Commission today announced that Christina M. Thomas will rejoin the Division of Corporation Finance in February as deputy director and chief advisor on disclosure, policy, and rulemaking.“Christina brings her deep technical…
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FintechCrypto ExchangeAll Firms
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Crypto ExchangeFintech
The Securities and Exchange Commission today announced that Keith E. Cassidy has been appointed Director of the Division of Examinations. Mr. Cassidy has served as Acting Director since May 2024 and previously was the division’s Deputy Director, Acting…
BankBroker DealerAsset Manager No description available.
The CFTC announced three major enforcement actions on January 16, 2026, resolving cases involving **market manipulation (spoofing), misappropriation of confidential information, and unregistered commodity pool operations**. These cases demonstrate the CFTC's continued enforcement focus on fraudulent trading practices and registration violations, with combined penalties exceeding $685,000 and criminal sentences totaling over six years in prison.
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 requiring disgorgement of unlawful gains ($135,788) plus civil penalties ($200,000), with 18-month trading...
Suggested Considerations
- *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
- CFTC enforcement action filed against Smith and Nowak
- CFTC complaint filed against Miller and Omerta Capital; DOJ criminal charges filed
- CFTC complaint amended against Miller and Omerta Capital
- Smith and Nowak sentenced to prison (criminal case)
- Miller sentenced to prison (criminal case)
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
The CFTC has announced enforcement updates, including civil monetary penalties and trading bans for spoofing in precious metals futures markets and misappropriating confidential information. These updates highlight the importance of compliance with CFTC regulations. Firms must ensure they are registered and comply with anti-spoofing and anti-fraud regulations.
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.
Suggested Considerations
- 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
CFTC enforcement action filed against Gregg Smith and Michael Nowak
Department of Justice charged Peter Miller with conspiracy to commit commodities fraud
Peter Miller sentenced to five months in prison and five months of home confinement
Department of Justice charged Travis Ford with conspiracy to commit wire fraud
Potential Consequences
Enforcement action, fines, trading bans, and registration revocation
Related Regulations
Commodity Exchange ActCFTC regulations
Confidence: high
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerAsset ManagerCrypto Exchange The Securities and Exchange Commission today announced that J. Russell “Rusty” McGranahan has been named SEC General Counsel. As the SEC’s chief legal officer, Mr. McGranahan will oversee the provision of legal expertise and advice to the Office of the…
BankAsset ManagerBroker Dealer
The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing the…
The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.
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...
- Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
- Complements parallel Wells process reforms under Chairman Paul Atkins, including a baseline four-week response period, greater access to evidence, and senior-level meetings for transparency and due...
Suggested Considerations
- 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.g., prepare for four-week timelines and evidence access requests).
- 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
- Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.
- SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.
Compliance Impact
Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case resolutions and shift settlement dynamics, especially amid 2025's enforcement slowdown from staffing cuts (15-20% headcount reduction). Firms with active investigations should prioritize strategic adjustments now.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerBroker DealerHedge Fund No description available.
FintechCrypto Exchange
The Securities and Exchange Commission today announced it will hold its third and final outreach event to help firms comply with amendments to Regulation S-P. The event, which is focused on small firms, is open to in-person or virtual attendance, and is…
Asset ManagerBroker DealerWealth Manager The Securities and Exchange Commission’s Office of the Advocate for Small Business Capital Formation today published and delivered to Congress its 2025 staff report that serves as a comprehensive and data-rich resource on capital-raising dynamics…
Asset ManagerBroker DealerWealth Manager No description available.
Broker DealerCrypto Exchange
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BankBroker DealerCrypto Exchange
The Securities and Exchange Commission today announced that Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), concluded her tenure with the agency on December 26, 2025.“I am thankful to Nekia for answering the call to…
This SEC press release announces the departure of Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), who concluded her tenure on December 26, 2025, after overseeing enforcement investigations and litigations across Washington D.C., Atlanta, and Miami offices. It matters to compliance professionals as personnel changes in SEC Enforcement leadership can signal potential shifts in enforcement priorities, investigation focus, or regional scrutiny intensity in the Southeast U.S.
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.
Suggested Considerations
- related delays and monitor for successor announcements via https://www.sec.gov/newsroom/press-releases.
Key Dates
- Nekia Hackworth Jones concludes her tenure at the SEC
- SEC issues press release announcing the departure
Compliance Impact
Urgency: low - This is a routine leadership transition with no immediate regulatory or enforcement changes; it matters peripherally for firms anticipating shifts in SEC Enforcement priorities under new leadership, but lacks direct compliance obligations.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAll Firms
The Securities and Exchange Commission today announced that Cicely LaMothe, Deputy Director of the Division of Corporation Finance, has retired from the agency.“Cicely has gone above and beyond the call of duty over the past twenty-four years to serve…
Asset ManagerBroker DealerWealth Manager
No description available.
BankBroker DealerCrypto Exchange
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BankBroker DealerCrypto Exchange
The Securities and Exchange Commission today filed charges against purported crypto asset trading platforms Morocoin Tech Corp., Berge Blockchain Technology Co. Ltd., and Cirkor Inc. and investment clubs AI Wealth Inc., Lane Wealth Inc., AI Investment…
Crypto ExchangeBroker DealerAsset Manager
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BankBroker DealerCrypto Exchange
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The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
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.
Suggested Considerations
- *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. 23-01
- *Ongoing Compliance
Key Dates
- CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
- CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
- CFTC issued Notice of Proposed Rulemaking (comment period opened)
- Comment period deadline (ISDA and SIFMA submitted comments on this date)
- CFTC approved final rule (subject to pre-publication technical corrections)
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerBank
No description available.
BankBroker DealerCrypto Exchange
The Securities and Exchange Commission today announced that financial economist and academic scholar Dr. Joshua T. White will return to the agency beginning the week of Jan. 5, 2026, to serve as its Chief Economist and Director of the Division of…
Asset ManagerBroker DealerBank
The Securities and Exchange Commission’s Office of the Investor Advocate today delivered its Report on Activities for the Fiscal Year 2025 to Congress, highlighting the initiatives and work of the office during the fiscal year.The report includes:An…
Asset ManagerBroker DealerCrypto Exchange Election Notice - 12/16/2025
Broker DealerAsset Manager
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BankBroker DealerCrypto Exchange
The Securities and Exchange Commission today charged Canadian citizen Nathan Gauvin and three entities he controls—Blackridge, LLC, Gray Digital Capital Management USA, LLC, and Gray Digital Technologies, LLC—with orchestrating two fraudulent securities…
Broker DealerCrypto Exchange
The Securities and Exchange Commission today announced the agenda and panelists for its Dec. 16, 2025, roundtable on Rule 611 of Regulation NMS and other associated rules and regulatory requirements.The roundtable will be held at the University of Austin…
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Broker DealerAsset ManagerBank
The Securities and Exchange Commission today announced that Lori J. Schock, who has served as the Director of the Office of Investor Education and Assistance (OIEA) since 2009, will retire from the agency at the end of December.“I have known Lori for…
Asset ManagerBroker DealerWealth Manager
The Securities and Exchange Commission today announced it will hold the second in its series of compliance outreach events regarding the 2024 adoption of amendments to Regulation S-P. The event, for transfer agents, is a webinar scheduled for December 17…
Broker DealerAsset Manager
The Securities and Exchange Commission today announced that Cristina Martin Firvida, who has served as the Director of the Office of the Investor Advocate since January 2023, will conclude her tenure with the agency at the end of January 2026. As…
Asset ManagerWealth ManagerBroker Dealer
The Securities and Exchange Commission’s Investor Advisory Committee will hold a virtual public meeting on Dec. 4, 2025, at 10 a.m. ET. The meeting will be webcast on the SEC website.The committee will host two panels:Regulatory Changes in Corporate…
Broker DealerCrypto ExchangeAll Firms
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The CFTC filed a civil enforcement action on November 21, 2025, against Brian Mitchell, Kevin Mack Jr., and their unregistered entity Young Pros Investment Group LLC (YPIG) for fraudulently soliciting ~$1 million from 33 pool participants to trade commodity futures, using misrepresentations, Ponzi payments, false statements, and registration violations, including Mitchell's breach of a prior 2021 CFTC order. This case underscores the CFTC's aggressive enforcement against unregistered commodity pools and fraud, seeking restitution, disgorgement, penalties, trading bans, and injunctions under the Commodity Exchange Act (CEA). Compliance teams must prioritize registration checks and fraud prevention to avoid similar actions, as it highlights personal liability for controlling persons.
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...
- Prohibitions on fraud, misrepresentations, guarantees of profit, non-disclosure of risks, commingling funds, and operating pools as non-separate entities (CEA Section 4o, Regulations 4.20, 4.21).
- Compliance with prior CFTC orders barring trading or registration-required activities.
Suggested Considerations
- Verify registration: Check CFTC/NFA BASIC database before engaging with pools or advisors; unregistered status warrants avoidance.
- Implement controls: Segregate pool funds (Regulation 4.20), avoid commingling, disclose risks fully, prohibit profit guarantees/misrepresentations, and issue accurate statements.
- Conduct due diligence: Screen principals for prior CFTC orders; cease activities if barred.
- Train staff: On fraud red flags (e.g., Ponzi payments, high-yield promises) and report suspicions via CFTC hotline (866-FON-CFTC) or online tip form.
- For SEC-registered advisers: Evaluate eligibility for CFTC Letter 25-50 relief to avoid dual registration while ensuring pools limit to qualified eligible persons (QEPs).
Key Dates
May 2022; - Alleged fraudulent solicitation and trading period
- Prior CFTC administrative order against Mitchell (Press Release 8427-21) prohibiting trading and registration activities for three years
- CFTC files complaint in U.S. District Court for the Eastern District of Michigan
Compliance Impact
Urgency: High - This action signals intensified CFTC scrutiny on unregistered pools amid rising crypto/futures fraud (e.g., similar January 2026 case against Wolf Capital). It matters because penalties include personal bans, multimillion restitution/disgorgement, and whistleblower awards (10-30% of sanctions), amplifying financial/reputational risk; non-registration alone triggered charges alongside fraud. Firms with commodity exposure must audit operations immediately to preempt enforcement.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Hedge FundAsset ManagerAll Firms
The Securities and Exchange Commission’s Crypto Task Force has rescheduled its Financial Surveillance and Privacy Roundtable, previously scheduled for October, to Monday, Dec. 15, 2025.“I am looking forward to getting this event back on the calendar…
BankBroker DealerCrypto Exchange The Securities and Exchange Commission announced today that it will hold a roundtable on Dec. 16, 2025, to discuss Rule 611 of Regulation NMS and other, associated rules and regulatory requirements. This roundtable is a follow-up to the SEC’s Sept. 18,…
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The CFTC today announced the U.S. District Court for the Central District of California entered a final judgement against Safeguard Metals LLC and Jeffrey Ikahn (aka Jeffrey Santulan and Jeffrey Hill) ordering them to pay $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for operating a nationwide, precious metals fraud. Released: 11/20/2025
The CFTC, alongside 30 state regulators, secured a final judgment on November 20, 2025, against Safeguard Metals LLC and Jeffrey Ikahn, imposing $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for a nationwide precious metals fraud scheme from October 2017 to July 2021 that defrauded over 450 elderly investors of more than $52 million. This enforcement action, resolving a February 2022 complaint, highlights coordinated federal-state-SEC efforts to combat commodity fraud and underscores personal liability for controlling persons under CEA Section 6(c)(1) and Regulation 180.1(a). It matters for compliance as it reinforces aggressive penalties for misrepresentations, overcharges, and targeting vulnerable populations, with offsets across parallel SEC proceedings.
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.
Suggested Considerations
- 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
- CFTC and states file initial complaint alleging fraud scheme
- Plaintiffs file First Amended Complaint
- Second Amended Complaint filed
- Court enters SEC remedies judgment ($25.6M disgorgement/penalty, with offsets)
- Court issues Statement of Decision granting restitution ($25.6M) and civil penalty ($25.6M)
Compliance Impact
Urgency: Medium - This resolved enforcement sets precedent for precious metals fraud penalties but imposes no new rules or immediate deadlines beyond whistleblower claims (March 9, 2026). It matters due to escalating CFTC-state coordination, personal liability risks, and focus on elder fraud amid rising retail commodity scams; firms in metals or alternatives face audit risks if sales practices mirror the scheme (e.g., overcharges, false safety claims).
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerAsset ManagerAll Firms
No description available.
Broker DealerCrypto Exchange
The Securities and Exchange Commission’s Division of Examinations today released its 2026 examination priorities. The Division publishes its annual examination priorities to provide transparency to registrants and investors about the topics that the…
Asset ManagerBroker DealerCrypto Exchange
The Securities and Exchange Commission today announced that Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), will conclude her tenure with the agency effective Dec. 1, 2025. “I thank Antonia for her steadfast leadership in…
This SEC press release announces the departure of Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), effective December 1, 2025. It signals ongoing leadership transitions within the restructured Enforcement Division under new SEC Chair Paul Atkins, which may influence enforcement priorities, transparency, and regional consistency, requiring firms to adapt compliance strategies amid a "return to basics" approach focused on core investor protection.
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, now requiring direct Commission authorization to align with priorities.
- Emphasis on transparency, such as sharing legal theories and evidence with defense counsel during Wells processes, rewarding cooperation, self-reporting, and remediation, while avoiding novel legal...
Suggested Considerations
- 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
- SEC rescinded delegation of formal order authority to Enforcement Director
- Nekia Hackworth Jones appointed Deputy Director (Southeast)
- Margaret A. Ryan appointed Director of Enforcement
- SEC announced Apps' departure
- Antonia M. Apps concludes her tenure as Deputy Director of Enforcement (Northeast).
Compliance Impact
Urgency: Low - This is a routine personnel change with no immediate regulatory shifts or deadlines post-December 1, 2025. It matters indirectly as part of 2025's Enforcement Division overhaul (15% headcount reduction, regional consolidation), likely leading to prioritized, transparent enforcement on retail harm and core violations rather than expansive theories—firms should prepare for efficiency-driven probes but face no urgent overhauls.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAsset ManagerAll Firms
The Securities and Exchange Commission today issued an order granting temporary exemptive relief from certain compliance dates adopted under Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders as follows:…
Broker DealerBank
The Securities and Exchange Commission today announced that Stacey Bowers, who has served as the Director of the Office of the Advocate for Small Business Capital Formation, will depart the agency effective October 17, 2025. She has served as Director…
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Election Notice - 1/10/2025
Broker DealerAsset ManagerAll Firms
The Securities and Exchange Commission today enhanced its efforts to assist broker-dealers and other market participants on the path to central clearing of U.S. Treasury securities, developing a one-stop webpage that puts the latest status updates, staff…
Broker DealerBank
The Securities and Exchange Commission today issued an order granting conditional exemptive relief related to certain requirements of the National Market System Plan governing the Consolidated Audit Trail (CAT NMS Plan), Rule 613 of Regulation NMS, and…
Broker DealerAsset Manager
No description available.
BankBroker DealerCrypto Exchange
The Securities and Exchange Commission today published a concept release soliciting public comment on how to improve current SEC rules governing residential mortgage-backed securities (RMBS) and certain aspects of asset-backed securities (ABS) generally…
BankBroker DealerAll Firms
No description available.
Asset ManagerBroker DealerBank
The Securities and Exchange Commission today announced that Ken Johnson, who has been serving as Chief Operating Officer (COO) since December 2017, will retire from the agency in December. “Ken has been an integral leader at the SEC for more than two…
BankAsset ManagerBroker Dealer
No description available.
Broker DealerCrypto ExchangeAll Firms
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The CFTC issued an order on September 17, 2025, sanctioning Shinhan Securities Co. Ltd. with a $212,500 civil monetary penalty for engaging in wash sales and non-competitive transactions on NYMEX, involving near-simultaneous bids and offers for the same futures contracts under the same beneficial owner to avoid risk and price competition. This enforcement action underscores the CFTC's ongoing focus on market manipulation practices that undermine open and competitive trading, serving as a reminder for firms to enhance trade surveillance and compliance programs. Compliance professionals should note this as evidence of active CFTC scrutiny on wash trading violations under the Commodity Exchange Act (CEA).
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 with the same beneficial owner, even if enhancing execution likelihood.
Suggested Considerations
- Enhance trade surveillance: Implement or upgrade systems to detect near-simultaneous bids/offers for identical futures contracts across related accounts, flagging same-beneficial-owner trades.
- Conduct gap analysis: Review historical trades for wash sale patterns, including non-competitive executions that offset risk; remediate via training and policy updates.
- Strengthen internal controls: Ensure separation of buy/sell orders to maintain genuine price competition; document beneficial ownership to avoid inadvertent violations.
- Self-reporting consideration: If potential violations identified, evaluate voluntary disclosure per CFTC's February 25, 2025, Enforcement Advisory for mitigation credit, including immediate remediation steps like gap analyses and prevention plans.
- Training and recordkeeping: Train traders on CEA prohibitions (e.g., Sections 6(c)(2), 9(a)(2)); maintain detailed trade logs for CFTC audits.
Key Dates
- CFTC issues order filing and settling charges against Shinhan, requiring immediate payment of $212,500 penalty and cease-and-desist order
Compliance Impact
Urgency: Medium - This action signals sustained CFTC enforcement on wash sales amid broader anti-manipulation priorities, with penalties reflecting cooperation but still material ($212,500). It matters because wash trades erode market integrity, and recent advisories incentivize proactive remediation to reduce penalties; firms with similar trading patterns face heightened exam risk, especially post-2025 enforcement shifts toward disruptive practices like spoofing and wash trading.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
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Election Notice - 7/18/2025
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Election Notice - 5/15/2025
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