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1 – 2 of 2James Burns and Kimberly Beattie Saunders
To explain a settlement involving a foreign financial institution, its non-US subsidiaries, and the US Securities and Exchange Commission (“SEC”) that reveals an SEC focus on…
Abstract
Purpose
To explain a settlement involving a foreign financial institution, its non-US subsidiaries, and the US Securities and Exchange Commission (“SEC”) that reveals an SEC focus on policing the activities of foreign firms that reach into the United States and helps further define the scope of activities that require registration under the federal securities laws.
Design/methodology/approach
Provides insight into a recent area of focus for SEC regulators and introduces the potential regulatory implications for non-US firms with activities that reach into the United States.
Findings
Given the SEC’s current enforcement focus, it is critical that financial institutions take care to conduct their activities with an understanding of the regulatory requirements associated with the provision of brokerage and advisory services to US clients and customers – including, for many firms, registration as an investment adviser, broker-dealer, or both.
Originality/value
Practical regulatory guidance regarding SEC registration requirements that may reach non-US firms from experienced financial services lawyers specializing in asset management.
Details
Keywords
James R. Burns, James E. Anderson, Kimberly Beattie Saunders and Charles F. Gyer
To describe the steps taken by the SEC to shorten the standard settlement cycle for most broker-dealer transactions from three business days to two business days after the trade…
Abstract
Purpose
To describe the steps taken by the SEC to shorten the standard settlement cycle for most broker-dealer transactions from three business days to two business days after the trade date.
Design/methodology/approach
Provides insight into a recent area of focus for SEC regulators and describe the SEC’s efforts to improve the efficiency of and reduce risks associated with the US national clearance and settlement system.
Findings
Industry participants must continue to work toward an migration date from T+3 to T+2 on September 5, 2017. In addition, numerous corresponding rule changes have been made or are expected across other regulatory regimes, including other federal regulators and self-regulatory organizations. Industry participants should monitor communications from these organizations closely for guidance about regulatory updates related to T+2.
Originality/value
Practical regulatory guidance regarding SEC operational requirements for the US national clearance and settlement system and the impact on related SEC regulations from experienced securities lawyers.
Details