Compliance Content

Last month, FINRA filed with the SEC proposed amendments to Rule 2210 (Communications with the Public) (the "rule"). If adopted, the amendments would permit a FINRA member to project the performance or provide a targeted return with respect to a security or asset allocation or other...

On November 27, 2023, the Securities and Exchange Commission (SEC or "Commission"), on a 4-1 vote by seriatim, adopted Rule 192 ("Final Rule") under the Securities Act of 1933 ("Securities Act"), which implements the prohibition under Section 621 of the Dodd-Frank Act on material...

On December 11, 2023, Investment Company Institute (ICI) submitted comments to the Commodity Futures Trading Commission (CFTC) regarding its proposed amendments to Regulation 4.7 (the "Proposal"). While the Proposal contained several proposed amendments that would affect commodity...

The Office of Information and Regulatory Affairs released the Fall 2023 Unified Agenda of Regulatory and Deregulatory Actions on December 6, 2023. The agenda includes regulatory actions that the Securities and Exchange Commission and Commodity Futures Trading Commission expect to take...

Last month, FINRA filed with the SEC proposed amendments to Rule 2210 (Communications with the Public) (the "rule"). If adopted, the amendments would permit a FINRA member to project the performance or provide a targeted return with respect to a security or asset allocation or other...

Last week, the Securities and Exchange Commission stayed amendments that will require enhanced disclosure when an issuer repurchases its own equity securities ("Share Repurchase Rule"). The Commission stayed the amendments in light of a decision from the U.S. Court of Appeals for the...

On October 31, 2023, the Department of Labor (DOL) released its long-awaited new regulatory package on fiduciary investment advice. The package includes a proposal to amend the regulation defining who is a "fiduciary" under section 3(21) of ERISA and section 4975(e)(3) of the Internal...

For the twelfth year in a row, the SEC office responsible for conducting inspections of registrants, the Division of Examinations, has published its examination priorities for the coming year. While the Division has commonly published its examination priorities near the beginning of...

On October 10, the SEC adopted final amendments to its rules governing beneficial ownership reporting on Schedules 13D and 13G ("Final Rules"). We are pleased that the Final Rules reflect many of ICI's comments. The Final Rules were approved by the Commission by a 4-1 vote...