Susan Light

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On March 25, the Securities and Exchange Commission issued an Order granting the application by the Financial Information Forum (FIF) and Securities Traders Association (STA) for a temporary exemption from certain requirements of Rule 606 of Regulation NMS under the Securities Exchange Act of 1934, which requires broker-dealers to disclose certain information regarding the handling…

On March 24, the Securities and Exchange Commission, on behalf of the staffs of the Division of Corporation Finance, the Division of Investment Management and the Division of Trading and Markets issued an announcement with respect to the authentication document retention requirements of Rule 302(b) of Regulation S-T in light of health, transportation and other logistical issues raised by the spread of COVID-19. Rule 302(b) requires that each signatory manually sign a signature page or other document authenticating his or her signature that appears in typed form within the electronic filing with the SEC.…
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On March 22, the Securities and Exchange Commission announced that registered transfer agents and certain other persons would be provided with conditional relief from their regulatory obligations under federal securities laws through May 30, 2020. Among other conditions, persons that wish to avail themselves of the regulatory relief must provide written notice to the SEC…

On March 19, the Securities and Exchange Commission approved a proposed rule change filed by Cboe Exchange, Inc. (CBOE) related to permissible off-floor position transfers. Generally, CBOE requires a Trading Permit Holder (TPH) to effect transactions in listed options on an exchange. However, certain types of transfers involving TPH positions are permitted to be effected off the exchange. The approved rule change adds four types of additional off-floor transfers:…
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On March 20, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-20 regarding recent amendments to FINRA Rule 5110 (Corporate Financing Rule – Underwriting Terms and Arrangements), which requires member firms participating in a public offering to file certain documents and information with FINRA regarding the underwriting terms arrangements. …
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On February 20, the Financial Industry Regulatory Authority (FINRA) released a targeted examination letter requesting that certain member firms provide information related to their decision not to charge commissions for customer transactions and its impact on firms’ order routing practices and decisions. The letter requests details regarding the type of securities in which a firm effects customer transaction without a commission, the factors a firm considers in deciding whether or not to charge a commission, and other aspects of a firm’s business.…
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On February 27, the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 20-07, reminding member firms of their supervisory responsibilities with respect to supervise Uniform Transfers to Minors Act and Uniform Gifts to Minors Act accounts (collectively, UTMA/UGMA Accounts). UTMA/UGMA Accounts are custodial accounts that allow a donor to transfer funds, securities and other assets…

On February 26, Commissioner Hester Peirce of the Securities and Exchange Commission filed a dissent to the SEC’s decision to reject a proposed rule change from NYSE Arca that would have allowed it to list shares of an exchange-traded fund backed by bitcoin and US Treasury bills. In her dissent, Commissioner Peirce argued that the…

On February 14, the Securities and Exchange Commission proposed to modernize the infrastructure for the collection, consolidation and dissemination of market data for exchange-listed national market system (NMS) securities, including by expanding the content of included NMS market data and introducing a decentralized consolidation model with competing data consolidators.…
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On February 18, the Financial Industry Regulatory Authority (FINRA) issued a regulatory notice seeking comment on a proposal to implement recommendations of the Securities Industry/Regulatory Council on Continuing Education, enhancing the continuing education requirements for securities industry professionals.…
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