FINRA Clarifies Guidance On Best Execution And Payment For Order Flow

The Financial Industry Regulatory Authority (FINRA) recently issued a Regulatory Notice (Notice) reminding firms of their obligations with respect to best execution and payment for order flow.1

These topics received a great deal of attention in recent months from both regulators and the industry, as heightened levels of trading activity by retail investors impacted broader markets (for example, the GameStop “short squeeze” and other trading patterns in so-called “meme” stocks). Many of these retail investors […]

By | August 10th, 2021 ||

Firm Settles NYSE Arca And NYSE American Charges For Notification Failures On Securities Offerings

An investment banking and broker-dealer firm settled NYSE Arca and NYSE American charges for failing to submit, or submit in a timely manner, notifications in connection with its engagement in the distribution of securities. The firm settled related charges with FINRA for its failure to timely file notifications under SEC regulations prohibiting manipulation of securities offerings (“Regulation M”).

In its Letter of Acceptance, Waiver, and Consent (“AWC”), NYSE Arca found that the firm failed to timely and accurately submit Restricted Period […]

By | August 8th, 2021 ||

Cross Trades And Principal Transactions – Recent SEC Guidance Relevant For CLO Managers

Our Investment Management Alert from earlier this month described to private fund advisers the importance of the Security Exchange Commission’s (SEC’s) Division of Examinations recent Risk Alert on cross trades and principal transactions. That Risk Alert, issued on July 21, 2021, included guidance and warnings based on more than 20 examinations of investment advisers that engaged in cross trades or principal transactions involving fixed income instruments. As SEC-registered advisers, the SEC’s observations and guidance are equally […]

By | August 4th, 2021 ||