Broker-Dealer Advisory & Counseling

  • Representing a broker-dealer in a FINRA investigation and enforcement action relating to mutual fund sales practices.
  • Reviewing and negotiating clearing and related agreements between client broker-dealers and clearing firms.
  • Reviewing and counseling broker-dealers on electronic record-keeping of transactional and financial records, including WORM compliance.
  • Preparing a FINRA continuing membership application relating to a client’s consolidation of affiliated broker-dealers.
  • Assisting a broker-dealer in a FINRA inquiry regarding fixed income pricing, mark-ups, and best execution.
  • Assisting broker-dealer clients with regulatory examinations and investigations.
  • Advising broker-dealers on various aspects of their electronic trading platforms.
  • Advising a broker-dealer in connection with its electronic blue sheet submissions to regulators.

Looking Forward

In 2020, securities regulators likely will focus on issues relating to new digital currency products, interpretive advice on new Regulation BI, cybersecurity compliance, implementation of the amendments to Rule ATS, financial responsibility compliance, new uses of blockchain and artificial intelligence technologies in trading and trade processing, conflicts of interest and best execution, and decisions on trading rule pilots. The SEC and FINRA likely will increase focus on cybersecurity policies and procedures as well as continue to investigate compliance with anti-money laundering regulations.