The SEC Adopts FINRA Rule 2081 in an effort to boost the integrity of the CRD System

The SEC approved a new FINRA rule (FINRA Rule 2081) prohibiting member firms and associated persons from conditioning the settlement of a customer dispute on expungment relief from the Central Registration Depository (“CRD”).  The CRD system is an online registration and licensing database maintained by FINRA, pursuant to FINRA rules and an agreement with the North American Securities Administrators Association…

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BROKER DEALERS MUST IMPLEMENT REVIEW OF INTERNAL COMMUNICATIONS BY DEC. 1, 2014

DWH Legal Chicago Attorneys                                              Rule Alert: REVIEW OF INTERNAL COMMUNICATION December 1, 2014: Deadline for broker- dealers to implement review of internal communications related to investment banking and securities business under new FINRA Supervision rule 3110(b)(4). Expanded Requirements: Rule 3110(b)(4) expands broker-dealer communications review to include internal communications by all firm employees related to the member’s investment banking or…

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BE WARY OF WEARING TOO MANY HATS

DWH Legal Chicago Attorneys Investment management firms should make the effort to segregate the operations of affiliated entities that avail themselves of the separate registration exemptions under the Advisers Act for Private Fund Advisers,[1] Venture Capital Fund Advisers,[2] Foreign Private Advisers,[3] and Family Office Advisers.[4] In two administrative proceedings issued June 20, the SEC determined that two affiliated advisory entities,…

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