Senior Managers / Governance Regulations in United States

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

19 May 2026

- 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.

References

AI-generated analysis. May contain errors or omissions — verify with the original CFTC source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading Investment Management Crypto & Digital Assets

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerHedge Fund

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🇺🇸 SEC Enforcement high

May 18th 2026

SEC Rescinds Policy Regarding Denials of Settlements in Enforcement Actions

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…

AI Analysis

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

18 May 2026

- 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

TBD

- 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.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Investment Management Capital Markets & Trading Banking & Credit

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerBank

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🇺🇸 CFTC News

May 18th 2026

CFTC Chairman Selig Announces DJ Hennes as Director of the Market Participants Division

No description available.

Sectors:

Capital Markets & Trading Crypto & Digital Assets

Topics:

Authorisation & Licensing Senior Managers / Governance

All Firms

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🇺🇸 SEC Enforcement medium

April 8th 2026

SEC Appoints David Woodcock as Director of the Division of Enforcement

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…

AI Analysis

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

March 2026

- Prior Director Margaret Ryan resigned after approximately six months in the role amid reported disagreements on enforcement priorities

May 4, 2026

- 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.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading Investment Management Crypto & Digital Assets

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerHedge Fund

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🇺🇸 FINRA regulatory_notice low

March 17th 2026

Special Notice – 3/17/26

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.

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

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🇺🇸 SEC Enforcement high

March 16th 2026

SEC Announces Enforcement Division Director Judge Margaret A. Ryan Has Resigned From Agency

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…

AI Analysis

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

February 11, 2026

- Director Ryan delivered public remarks outlining enforcement priorities and Wells process commitments

February 24, 2026

- SEC announced comprehensive updates to Enforcement Manual (first update since 2017)

March 17, 2026

- Judge Margaret A. Ryan's resignation announced; Sam Waldon named Acting Director (effective immediately)

Ongoing

- 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

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading Investment Management Banking & Credit

Topics:

Reporting & Disclosure Senior Managers / Governance Authorisation & Licensing

Broker DealerAsset ManagerBank

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🇺🇸 CFTC News medium

March 9th 2026

CFTC Announces Marc H. Sielski as Executive Director

No description available.

Sectors:

Banking & Credit Capital Markets & Trading Payments & E-Money

Topics:

Operational Resilience / Outsourcing Authorisation & Licensing Senior Managers / Governance

BankBroker DealerFintech

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🇺🇸 CFTC News medium

March 6th 2026

CFTC Chairman Selig Announces Departure of Senior Advisor Brigitte Weyls

No description available.

Sectors:

Capital Markets & Trading Crypto & Digital Assets

Topics:

Authorisation & Licensing Senior Managers / Governance

Broker DealerCrypto Exchange

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🇺🇸 SEC policy_statement critical

February 27th 2026

SEC Adopts Final Rules for the Holding Foreign Insiders Accountable Act

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…

AI Analysis

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

December 18, 2025

HFIA enacted into law

February 27, 2026

SEC adopts final rules (ahead of 90-day mandate)

March 18, 2026 DEADLINE

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

Ongoing

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.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading

Topics:

Reporting & Disclosure Senior Managers / Governance

All Firms

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🇺🇸 SEC Enforcement high

February 24th 2026

SEC’s Division of Enforcement Announces Updates to Enforcement Manual

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…

AI Analysis

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

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerAsset Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Consolidated Reports

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerBank

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🇺🇸 FINRA regulatory_notice high

January 24th 2026

Conflicts of Interest

Sectors:

Banking & Credit Capital Markets & Trading Investment Management

Topics:

Consumer Protection / Conduct Market Abuse / Surveillance Senior Managers / Governance

Broker DealerBankAsset Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Central Registration Depository (CRD)

Sectors:

Investment Management Wealth & Private Banking Capital Markets & Trading

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerWealth ManagerAsset Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Carrying Agreements

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Branch Offices

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerWealth ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Books and Records

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Operational Resilience / Outsourcing Senior Managers / Governance

Broker DealerAsset ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-01

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerBank

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🇺🇸 FINRA regulatory_notice low

January 24th 2026

Special Notice – 5/15/25

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

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🇺🇸 FINRA Guidance high

January 24th 2026

Information Notice - 8/14/25

AI Analysis

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

October 1 (annually)

- FINRA publishes upcoming Regulatory Element topics by registration category

January 1, 2023

- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

July 1, 2024

- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

December 31, 2025 DEADLINE

- 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]

References

AI-generated analysis. May contain errors or omissions — verify with the original FINRA source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading

Topics:

Authorisation & Licensing Senior Managers / Governance

Broker DealerAll Firms

View Original

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-09

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Election Notice – 9/4/25

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerBank

View Original

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-13

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerBank

View Original

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Election Notice – 10/20/25

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

View Original

🇺🇸 FINRA regulatory_notice high

January 24th 2026

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…

AI Analysis

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

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset Manager

View Original

🇺🇸 SEC News

December 8th 2025

SEC Announces Departure of OIEA Director Lori J. Schock

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…

Sectors:

Investment Management Capital Markets & Trading Wealth & Private Banking

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerWealth Manager

View Original

🇺🇸 SEC News low

November 25th 2025

Cristina Martin Firvida to Conclude Tenure as Investor Advocate

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…

Sectors:

Investment Management Wealth & Private Banking Capital Markets & Trading

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Asset ManagerWealth ManagerBroker Dealer

View Original

🇺🇸 SEC Enforcement low

November 13th 2025

Deputy Director of Enforcement Antonia M. Apps to Conclude Her Tenure at the SEC

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…

AI Analysis

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

March 2025

- SEC rescinded delegation of formal order authority to Enforcement Director

April 2025

- Nekia Hackworth Jones appointed Deputy Director (Southeast)

September 2, 2025

- Margaret A. Ryan appointed Director of Enforcement

November 13, 2025

- SEC announced Apps' departure

December 1, 2025

- 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.