Susan Light

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On November 17, the Securities and Exchange Commission adopted amendments to Regulation S-T to permit the use of electronic signatures in executing documents submitted electronically to the SEC through EDGAR.…
Continue Reading SEC Adopts Amendments Permitting Use of Electronic Signatures for EDGAR Filings

On November 16, the Financial Industry Regulatory Authority (FINRA) filed with the Securities and Exchange Commission a proposed rule change to (1) adopt FINRA Rule 4111 (Restricted Firm Obligations), which would impose additional conditions on member firms with a history of misconduct; and (2) adopt FINRA Rule 9561 (Procedures for Regulating Activities Under Rule 4111) and amend FINRA Rule 9559 (Hearing Procedures for Expedited Proceedings Under the Rule 9550 Series) to create a new expedited proceeding to implement proposed Rule 4111.…
Continue Reading FINRA Files Proposed Rule Change to Address Firms With History of Misconduct

The Financial Industry Regulatory Authority (FINRA) announced that it is conducting a review of firms’ systems and procedures for providing waivers and rebates to customers through Rights of Reinstatement (ROR) on mutual fund purchases. …
Continue Reading FINRA Conducts Review of Waiver and Rebate Systems and Procedures with Respect to Mutual Fund ROR Purchases

On October 29, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-38, announcing FINRA’s adoption of a new rule to limit any associated person of a member who is registered with FINRA (a “registered person”) from being named a beneficiary, executor or trustee, or having a power of attorney or similar position of trust on behalf of a customer. New FINRA Rule 3241 (Registered Person Being Named a Customer’s Beneficiary or Holding a Position of Trust for a Customer) is designed to protect investors from undue and inappropriate influence over important financial decisions by requiring members to review its registered persons who are beneficiaries or hold positions of trust for customers.…
Continue Reading FINRA Adopts Rule to Restrict Registered Person’s Ability to be a Beneficiary or Hold Position of Trust

On October 15, the Financial Industry Regulatory Authority (FINRA) released an information notice (Notice) providing additional background on authentication techniques for firms to consider as they implement cybersecurity authentication programs.…
Continue Reading FINRA Releases Information Notice on Cybersecurity Authentication Methods

On October 20, the National Adjudicatory Council (NAC) of the Financial Industry Regulatory Authority (FINRA) revised the Principal Considerations in Determining Sanctions section of the FINRA Sanction Guidelines to expressly contemplate a customer’s age or physical or mental impairment. In connection therewith, FINRA released Regulatory Notice 20-37.…
Continue Reading FINRA Releases Regulatory Notice on Revised NAC Sanction Guidelines

On September 22, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-33 that requested comment on (1) proposed formal procedures to bring actions against non-associated persons who cheat or misbehave during a FINRA qualification examination and (2) related amendments to FINRA’s registration requirements rule and eligibility proceedings rules.…
Continue Reading FINRA Requests Comment on Proposed Proceeding Rule for Failures to Comply With Qualification Examinations Rules of Conduct, Registration Requirements and Eligibility Proceedings Rules

On September 28, the Securities and Exchange Commission announced that it will hold a roundtable on October 26 at which staff from the SEC and the Financial Industry Regulatory Authority (FINRA) will discuss initial observations on the implementation of Regulation Best Interest and Form CRS.…
Continue Reading SEC Staff to Host Roundtable on Regulation Best Interest and Form CRS on October 26