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Jan 3, 2025 | 
jdsupra.com | Bradley Berman
As a result of the Executive Order of December 30, 2024, the federal government will be closed on January 9, 2025, for President Carter’s funeral. The NYSE and the Nasdaq have also announced that those exchanges will be closed on January 9, 2025, for equities trading. There have been two more announcements related to January 9, 2025: The Depository Trust Company (DTC) announced that it and its subsidiaries will be open for cash and securities settlements.
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Oct 9, 2024 | 
jdsupra.com | Bradley Berman |Anna Pinedo
A broker-dealer failed to reasonably supervise its registered representatives when making recommendations of certain variable rate structured products (“VRSPs”), including fixed to floating rate steepeners and other variable rate principal-at-risk structured products, to 20 investors. The broker-dealer violated FINRA Rules 2111 (Suitability) and 3110 (Supervision). The behavior in question occurred prior to the adoption of Regulation Best Interest.
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Oct 9, 2024 | 
lexology.com | Bradley Berman |Anna Pinedo
A broker-dealer failed to reasonably supervise its registered representatives when making recommendations of certain variable rate structured products (“VRSPs”), including fixed to floating rate steepeners and other variable rate principal-at-risk structured products, to 20 investors. The broker-dealer violated FINRA Rules 2111 (Suitability) and 3110 (Supervision). The behavior in question occurred prior to the adoption of Regulation Best Interest.
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Sep 25, 2024 | 
jdsupra.com | Bradley Berman |Anna Pinedo
A broker-dealer (the “Dealer”) entered into a cease-and-desist order with the Securities and Exchange Commission for failing to maintain and enforce written policies and procedures reasonably designed to achieve compliance with the Compliance Obligation of Regulation Best Interest (“Reg BI”), thus willfully violating the General Obligation of Reg BI. The Dealer had written policies in place to ensure compliance with Reg BI with respect to offers and sales of structured notes.
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Aug 5, 2024 | 
jdsupra.com | Bradley Berman |Matthew Bisanz |Kimberly Hamm
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s experience since earlier revisions in 2020 and the regional bank failures of 2023. This is generally accomplished by undoing key elements of the 2020 revisions and would dramatically expand the number of deposit brokers and the amount of deposits that are brokered.
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Aug 1, 2024 | 
lexology.com | Matthew Bisanz |Jeffrey Taft |Anna Pinedo |Andrew Olmem |Kimberly Hamm |Bradley Berman
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s experience since earlier revisions in 2020 and the regional bank failures of 2023. This is generally accomplished by undoing key elements of the 2020 revisions and would dramatically expand the number of deposit brokers and the amount of deposits that are brokered.
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Jul 4, 2024 | 
mondaq.com | Matthew Bisanz |Bradley Berman |Jerry Marlatt |Anna Pinedo
On May 22, 2024, the Financial Stability Board (FSB) issued a
report on vulnerabilities in the markets for commercial paper (CP)
and negotiable certificates of deposit (CDs). The report analyzes
the structure of the markets, identifies vulnerabilities, and
suggests reforms that policy makers might consider. It acknowledges
that limitations exist, and, therefore, the adoption of the reforms
will vary by industry as well as by regional and national
authorities.
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Jul 3, 2024 | 
jdsupra.com | Bradley Berman |Matthew Bisanz |Jerry Marlatt
On May 22, 2024, the Financial Stability Board (FSB) issued a report on vulnerabilities in the markets for commercial paper (CP) and negotiable certificates of deposit (CDs). The report analyzes the structure of the markets, identifies vulnerabilities, and suggests reforms that policy makers might consider. It acknowledges that limitations exist, and, therefore, the adoption of the reforms will vary by industry as well as by regional and national authorities.
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Jan 3, 2024 | 
lexology.com | Bradley Berman
Here’s the deal:The Trust Indenture Act of 1939 regulates the offer and sale of certain debt securities. For offerings of registered debt securities, an indenture must be qualified under the Trust Indenture Act as a condition of effectiveness of the related registration statement. The form of indenture and the Form T-1 must be included in the registration statement at the time of effectiveness.
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Dec 20, 2023 | 
jdsupra.com | David S. Bakst |Bradley Berman |David Freed
December 20, 2023 David Bakst, Bradley Berman, David Freed Mayer Brown Free Writings + Perspectives + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Here’s the deal: Regulation FD is an issuer disclosure rule that prohibits a US public company and certain persons acting on its behalf from selectively disclosing material nonpublic information about itself or its securities to certain persons outside the company unless it also...
