Journal of Investment Compliance: Volume 12 Issue 1

Competitive forces and cost‐based analysis in SEC review of SRO market data fee filings: NetCoalition v. Securities and Exchange Commission

Edward J. Ferraro

This paper aims to analyze and discuss the implications of the August 2010 decision of the D.C. Circuit Court of Appeals vacating and remanding to the SEC its December 2008 order…

Corporate ownership interests hidden through cash‐settled equity derivatives: impact on the companies' governance under the Italian legal framework

Gabriella Opromolla

This paper seeks to analyze the impact on companies' governance of corporate ownership interests hidden through cash‐settled equity derivatives.

FINRA IPO Allocation Rule; investment funds must now consider compliance

Russell Sacks, Michael Blankenship, Steven Blau

The purpose of this paper is to describe the Financial Industry Regulatory Authority's new rule for IPO allocation and the requirements for compliance with the rule.

Electronic trading agreements

Beth Alter, Lauri Goodwyn

This paper aims to analyze various issues a hedge fund manager should consider prior to executing any electronic trading agreement with a prime broker.

Commodities tax compliance challenges: Dodd‐Frank and beyond

Roger D. Lorence

The purpose of this paper is to highlight the continuing diligence required of the tax compliance function of any investment vehicle that holds commodities contracts. In addition…

Regulatory change for financial institutions: crossing the ocean in an open boat

Dermot Turing, Marc Benzler, Frédérick Lacroix

This paper aims to draw some overall conclusions and suggest a general approach financial institutions might take in response to all the different countries' recent financial…

PWG issues report on money market fund reform options

Stephen H. Bier, Thomas C. Bogle, Jack W. Murphy, Kevin K. Babikian, Sean R. Murphy

This paper seeks to explain the possible options detailed in the “Money Market Reform Options” report released by the President's Working Group on Financial Markets on October 21…

SEC issues guidance to boards reviewing certain affiliated transactions

Diane E. Ambler, Mark R. Greer

This paper seeks to explain recently published guidance from the Securities and Exchange Commission clarifying the responsibilities of mutual fund directors when they make the…

SEC approves rule banning “naked access” to trading centers

W. Hardy Callcott, Timothy C. Foley

This paper sets out to explain the new Securities and Exchange Commission Rule 15c3‐5, which will require broker‐dealers to adopt and implement risk controls to govern their…

SEC approves sweeping changes to FINRA's regulatory reporting rules

Harry J. Weiss, Yoon‐Young Lee, Bruce H. Newman, Paul R. Eckert, Claire R. Hanselmann

This paper seeks to explain Financial Industry Regulatory Authority (“FINRA”) Rule 4530, which requires members to report to FINRA certain internal and external findings of…

Summary of selected FINRA Regulatory Notices October‐December 2010

Henry A. Davis

The purpose of this summary is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) Regulatory Notices and Disciplinary Actions issued in October…

Editor column

Henry A. Davis

A new company descriptor takes us into a new era

Rebecca Marsh