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FINRA Announces Rule 2273, Requiring Broker’s New Firm to Send “Educational Communication” to Broker’s Customers Before Transfer of the Customer’s Assets to the New Firm
  • Greenberg Traurig LLP
  • USA
  • May 25 2016

FINRA has issued a regulatory notice (RN 16-18) regarding new Rule 2273, which requires member firms, when hiring a new broker from the competition


Omnicare Applied to Audit Reports by the Second Circuit
  • Greenberg Traurig LLP
  • USA
  • May 23 2016

On Friday, May 20, 2016, the Second Circuit issued the first opinion by a Circuit Court applying the Supreme Court's Omnicare decision to audit


SEC Issues No-Action Letter on Custody Rule
  • Greenberg Traurig LLP
  • USA
  • May 2 2016

On April 25, 2016, the SEC issued a no-action letter to the Investment Advisers Association clarifying its views on the application of Rule 206(4)-2


Not Every Broker-Dealer is an EB-5 Broker-Dealer
  • Greenberg Traurig LLP
  • USA
  • April 18 2016

Nearly all U.S. broker-dealers are members of the Financial Industry Regulatory Authority (FINRA). FINRA regulates, and provides oversight and


Best Buy: First Appellate Decision Interpreting and Applying Halliburton II Rejects Class Certification Based Upon the Absence of “Front-End” Price Impact
  • Greenberg Traurig LLP
  • USA
  • April 15 2016

On April 12, 2016, the Eighth Circuit Court of Appeals in IBEW Local 98 Pension Fund v. Best Buy Co., Inc., et al., CV No. 14-3178, became the first


SEC Seeks Additional Resources for Examination and Enforcement in FY 2017 Budget Request
  • Greenberg Traurig LLP
  • USA
  • April 7 2016

The Securities and Exchange Commission (SEC) recently presented the President's Fiscal Year 2017 budget request for the SEC to Congress. Among the


OCC Issues New Guidance and Policies on Enforcement Actions and Civil Monetary Penalties Against Institutions and Individuals
  • Greenberg Traurig LLP
  • USA
  • April 4 2016

The Office of the Comptroller of the Currency (“OCC”) recently released new guidance on the process it uses when considering enforcement actions


The Dutch Act on Collective Settlement of Mass Claims (WCAM) Goes Global Again: A Forum Outside the United States to Resolve Mass Claims Disputes Internationally
  • Greenberg Traurig LLP
  • Netherlands, USA
  • March 29 2016

On March 14, 2016, Ageas (formerly, Fortis Bank) and several foundations representing the Fortis shareholders announced a EUR 1.204 billion


Section 162(m): Actions that Should be Taken by March 30, 2016, andor in this Year’s Proxy to Avoid the $1,000,000 Deduction Limitation
  • Greenberg Traurig LLP
  • USA
  • March 22 2016

This GT Alert serves to remind our publicly held clients of things that need to be done early this year to minimize or avoid the application of the


Propriety of Constitutional Challenges to Agency Administrative Proceedings Discussed by Federal Regulators, and Supported by at Least One
  • Greenberg Traurig LLP
  • USA
  • March 16 2016

Top enforcement chiefs from the SEC, CFTC, DOJ and FINRA participated on a panel discussion of current enforcement trends and issues during the