The Securities and Exchange Commission (SEC) has proposed to amend Rule 15c2-11, which governs the publication and submission of quotations by a broker-dealer in the over-the-counter (OTC) market. The proposed amendments would prohibit a broker-dealer from publishing quotes in a security not listed on a national securities exchange unless documents and information about the issuer are current and publicly available.

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The Financial Industry Regulatory Authority (FINRA) has amended its Rule 2210 (Communications with the Public) and Rule 2241 (Research Analysts and Research Reports) to conform to the requirements of the Fair Access to Investment Research Act of 2017 (FAIR Act) and subsequent rules adopted by the Securities and Exchange Commission (SEC). As background, the FAIR Act and related SEC rules establish a safe harbor under which unaffiliated broker-dealers may publish and distribute research reports on “covered investment funds” without the publication or distribution being deemed an offer of securities. For these purposes, the term “covered investment funds” generally includes registered investment companies, business development companies, and certain commodity- and currency-based trusts and funds.

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On September 19, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-31 (Notice) addressing disclosure innovations in advertising and other communications with the public. The Notice responds specifically to questions that FINRA has received from member firms about how they can comply with FINRA rules when communicating with their customers. FINRA’s goal in issuing the Notice is to help facilitate simplified and more effective disclosures.
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The Financial Industry Regulatory Authority (FINRA) is proposing to expand TRACE reporting requirements to include transactions in U.S. dollar-denominated foreign sovereign debt securities. Under the proposal, this transaction information would be reported for regulatory purposes and would not be publicly disseminated.

Comments on the proposal must be submitted to FINRA by September 24, 2019.


The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued an advisory clarifying that the initial margin documentation requirement for swap dealers does not apply until the initial margin amount exceeds the regulatory posting threshold of $50 million (which is measured on a group basis). More specifically, DSIO’s