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.
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 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
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…
All Firms
No description available.
All Firms
No description available.
All Firms
No description available.
All Firms
No description available.
All Firms
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
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 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 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 DealerWealth ManagerAll Firms
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.
Hedge FundAsset Manager
No description available.
Crypto ExchangeFintech
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 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.
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
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
The Securities and Exchange Commission (SEC) today issued an interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets. This is a major step in the Commission’s efforts to provide…
Crypto ExchangeFintech
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
No description available.
Crypto ExchangeFintech
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.
Broker DealerCrypto ExchangeAll Firms
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
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
Regulatory Notice 26-05
Broker DealerWealth ManagerBank
No description available.
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 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.
Asset ManagerBroker DealerWealth Manager
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
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 DealerWealth ManagerBank
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.
BankBroker DealerHedge Fund
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
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
Equity-Indexed Annuities
Broker DealerWealth ManagerAsset Manager
Engagement
Broker DealerAsset ManagerWealth Manager
Enforcement Process
Broker DealerAsset ManagerWealth Manager
Enforcement
Broker DealerAsset ManagerWealth Manager
Electronic Fingerprint Processing
Broker DealerAsset ManagerWealth Manager
Electronic Communications
Broker DealerAsset ManagerWealth Manager
Direct Participation Programs (DPPs)
Broker DealerAsset ManagerWealth Manager
Digital Experience Transformation (DXT)
Broker DealerAsset ManagerWealth Manager
Derivatives and Other Balance Sheet Items (OBS)
Broker DealerAsset ManagerBank
Derivatives
Broker DealerAsset ManagerWealth Manager
Department of Labor
Broker DealerAsset ManagerWealth Manager
Deferred Annuities
Broker DealerAsset ManagerWealth Manager
Day Trading
Broker DealerAsset ManagerWealth Manager
Customer Orders
Broker DealerAsset ManagerWealth Manager
Customer Information Protection
Broker DealerAsset ManagerWealth Manager
Customer Account Transfers
Broker DealerAsset ManagerWealth Manager
Customer Account Statements
Broker DealerAsset ManagerWealth Manager
Crypto Assets
Crypto ExchangeBroker DealerAsset Manager
Credit for Cooperation
Broker DealerAsset ManagerBank
Correspondence
Broker DealerWealth ManagerAsset Manager
Corporate Financing
Broker DealerAsset ManagerBank
Corporate Bonds
Broker DealerBank
Continuing Education
Broker DealerWealth ManagerAsset Manager Consolidated Reports
Broker DealerAsset ManagerBank
Consolidated Audit Trail (CAT)
Broker DealerAll Firms
Comprehensive Automated Risk Data System (CARDS)
Broker DealerWealth ManagerAsset Manager
Compensation
Broker DealerAsset ManagerWealth Manager
Communications with the Public
Broker DealerWealth ManagerAsset Manager
Certificates of Deposit (CDs)
Broker DealerBankWealth Manager
Central Registration Depository (CRD)
Broker DealerWealth ManagerAsset Manager
Cash Equivalents
Broker DealerWealth ManagerBank
Carrying Agreements
Broker DealerAsset ManagerBank
Capital Formation
Broker DealerAll Firms
Business Continuity Planning
Broker DealerBankAsset Manager
BrokerCheck
Broker DealerWealth ManagerAll Firms
Broker-Dealer Recruitment Disclosures
Broker DealerWealth ManagerAll Firms
Breakpoints
Broker DealerWealth ManagerAsset Manager
Branch Offices
Broker DealerWealth ManagerBank
Books and Records
Broker DealerAsset ManagerBank
Bond Mutual Fund Volatility/Risk Rating
Asset ManagerBroker Dealer
Blue Sheets
Broker DealerAsset ManagerBank
Block Chain / Distributed Ledger Technology
Broker DealerFintechCrypto Exchange
Best Practices
Broker DealerAsset ManagerBank
Best Execution
Broker DealerAsset ManagerAll Firms
Auction Rate Securities
Broker DealerWealth ManagerAsset Manager
Asset Backed Securities
Broker DealerAsset ManagerBank
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
Algorithmic Trading
Broker DealerAsset ManagerFintech
Agency Bonds
Broker DealerBank
Advertising Regulation
Broker DealerAsset ManagerWealth Manager
529 Savings Plans
Asset ManagerWealth ManagerBroker Dealer
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 25-05
Broker DealerWealth ManagerAsset Manager
Regulatory Notice 25-06
Broker DealerAsset Manager
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 25-09
Broker DealerWealth ManagerBank
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
Regulatory Notice 25-13
Broker DealerWealth ManagerBank
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
Regulatory Notice 25-16
Asset ManagerBroker DealerWealth Manager Regulatory Notice 25-17
Broker DealerAsset ManagerBank
Regulatory Notice 25-18
Broker DealerWealth 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
No description available.
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 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…
All Firms
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 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 The Securities and Exchange Commission today proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for purposes of the Regulatory Flexibility…
The SEC proposed amendments on January 7, 2026, to expand the definitions of "small entities" under the Regulatory Flexibility Act (RFA) for registered investment advisers (RIAs), investment companies, and business development companies by significantly raising asset thresholds last updated in 1998. This would increase the number of qualifying small entities, enabling the SEC to better assess regulatory impacts and potentially provide tailored relief like extended compliance timelines during rulemaking. It matters because it could indirectly reduce compliance burdens for mid-sized firms by influencing future SEC rules to minimize disproportionate effects on smaller players.
What Changed
- - Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates.
- Increase the net asset threshold for investment companies from $50 million to $10 billion.
- Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification.
- Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulemaking.
- Make corresponding amendments to Form ADV and rules on continuing hardship exemptions for electronic filing.
Suggested Considerations
- Submit public comments by the deadline to influence thresholds, alternatives (e.g., client types, headcount), or exclusions (e.g., funds advised by small RIAs).
- Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www.sec.gov/rules-regulations/2026/01/s7-2026-01).
- Assess internal status: Calculate current RAUM/net assets against new thresholds to anticipate RFA benefits in upcoming rulemakings.
- No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules.
Key Dates
- SEC issues proposal and press release
- Public comment period closes (publication expected shortly after January 7; exact date TBD, likely March 2026 based on estimates)
- Typically at least one year post-comment period under normal processes
adoption; - Inflation adjustments to thresholds via SEC order
Compliance Impact
Urgency: Medium. This proposal does not impose direct new requirements or alter existing obligations—it's procedural for SEC's RFA analyses during rulemaking. However, adoption could lead to meaningful indirect benefits for mid-sized RIAs and funds, such as longer compliance phases or reduced burdens in rules on reporting, recordkeeping, or vendor reliance, addressing outdated 1998 thresholds amid industry AUM growth. Firms should engage now via comments to shape outcomes, but no urgent operational changes needed.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset Manager
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.
Asset ManagerBroker Dealer
No description available.
Broker DealerCrypto Exchange
No description available.
BankBroker DealerCrypto Exchange
No description available.
Broker DealerCrypto Exchange
No description available.
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
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
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…
Broker DealerAll Firms
No description available.
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
No description available.
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 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,…
Broker DealerAll Firms
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 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
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
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 Exchange
No description available.
BankBroker DealerCrypto Exchange Election Notice - 7/18/2025
Broker DealerAsset ManagerAll Firms
Election Notice - 5/15/2025
Broker DealerAsset ManagerAll Firms