Navigating Choppy Waters: Broker-Dealers and the Shifting Regulatory Tide
Join us for an afternoon break to chat about hot topics and trends relevant to your business. Our concise and practical discussions will focus on a variety of developments that impact financial service industries, and we’ll offer insights and considerations that will certainly be of interest
On July 21, 2025, to much welcome relief by investment advisers, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its postponement of the effective date of its recently issued anti-money laundering rule (IA AML Rule) from January 1, 2026 to January 1, 2028. The IA AML Rule requires certain registered investment
The Securities and Exchange Commission (SEC) is withdrawing a number of notices of proposed rulemaking due to changes in its priorities and the evolving regulatory landscape. While the SEC initially proposed changes in various areas affecting securities and investment practices, it has determined that no final rules will be issued regarding these proposals at this
The U.S. Securities and Exchange Commission (SEC) has announced the appointment of Brian T. Daly as the new Director of the Division of Investment Management, effective July 8, 2025. Daly, a highly regarded figure in the investment management industry, brings decades of experience advising fund managers and sponsors on regulatory compliance and legal matters.
Daly’s
On April 16, 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for the amendments to Form N-PORT. The SEC previously adopted amendments to Form N-PORT to require more frequent reporting of monthly portfolio holdings and related information, and to amend certain reporting requirements relating to entity identifiers. In the same release, the
On March 12, 2025, the SEC’s Division of Corporation Finance (the “Division”) issued a No Action Letter regarding the verification of accredited investor status for potential investors in a Rule 506(c) offering under Regulation D which may streamline verification requirements in such offerings.
Rule 506(c) under Regulation D broadly permits issuers to solicit and generally
On March 14, 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for the amendments to Rule 35d-1 (the Names Rule) under the Investment Company Act of 1940 (1940 Act). The Names Rule requires that a registered investment company invest at least 80% of the value of the fund’s net assets, plus the
The United States Securities and Exchange Commission – divided along political lines– sent to the trash heap a 15-year-old policy allowing its Director of Enforcement to approve new investigations as well as the issuance of subpoenas. See Delegation of Authority to Director of the Division of Enforcement, 17 CFR Part 200; Release Nos. 33-11366; 34-102552
From our SmartTrade Group at Thompson Hine!
President Trump issued the America First Investment Policy Memorandum on February 21, 2025 https://www.whitehouse.gov/presidential-actions/2025/02/america-first-investment-policy/ proclaiming that the United States “is committed to maintaining the strong, open investment environment that benefits our economy and our people, while enhancing our ability to protect the United States from new and evolving
The administration announced Thursday that it replaced the unit responsible for many of the SEC’s crypto registration suits with a new fraud-focused unit that will take a broader review of “cyber and emerging technologies.”
The Cyber and Emerging Technologies Unit will prioritize fraud cases that leverage novel tech including crypto, artificial intelligence, machine learning and