Senior Managers / Governance in United States

What Changed

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

What You Need To Do

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

Key Dates

References

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

What Changed

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

What You Need To Do

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

Key Dates

References

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

What Changed

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

What You Need To Do

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

Key Dates

References

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