John I. Sakhleh

Jul 9, 2024 | lexology.com | W. Hardy Callcott |Stephen Cohen |Ranah Esmaili |John I. Sakhleh |Charles Sommers |Daniel P. Atchue

On May 23, 2024, Gurbir S.

Apr 18, 2024 | lexology.com | Andrew Blake |John I. Sakhleh |Charles Sommers |Michael D. Wolk |Michael J. Ogershok |Jorge Ortiz

On March 6, 2024, in a unanimous vote, the U.S. Securities and Exchange Commission (SEC) adopted amendments to the disclosure requirements under Rule 605 of Regulation NMS for executions on covered orders in national market system (NMS) stocks (the Final Rule).1 The Final Rule seeks to modernize and enhance execution quality reporting and, among other things, (i) expands the scope of entities subject to Rule 605, (ii) modifies the categorization and content of order information required to be...

Apr 10, 2024 | lexology.com | Stephen Cohen |Chuck Daly |Ranah Esmaili |Lara Shalov Mehraban |Christopher Mills |David S. Petron | +2 more

On April 3, 2024, the U.S. Securities and Exchange Commission (SEC or Commission) announced an off-channel communications enforcement action that was the first such action against a private fund adviser and the first off-channel case against a standalone investment adviser since the SEC launched investigative sweeps focused on off-channel communications in 2022.1 The matter marks the latest in a series of enforcement actions for communications-related recordkeeping failures.

Feb 12, 2024 | lexology.com | Charles Sommers |Andrew Blake |W. Hardy Callcott |Kevin J. Campion |David Katz |Patrick M. Mellon | +2 more

On February 6, 2024, in a 3–2 vote along party lines, the U.S. Securities and Exchange Commission (SEC) adopted rules that further define what constitutes “dealer” or “government securities dealer” activity for purposes of the Securities Exchange Act of 1934 (Exchange Act).1 The adopted rules generally require any person that engages in a regular pattern of buying and selling securities (or government securities) that has the effect of providing liquidity to other market participants to have...

Oct 4, 2023 | lexology.com | Stephen Cohen |Ranah Esmaili |Lara Shalov Mehraban |Barry W. Rashkover |John I. Sakhleh |Lara C. Thyagarajan | +2 more

On September 29, 2023 — the last business day of its fiscal year — the U.S. Securities and Exchange Commission (SEC) issued the latest in a series of actions charging 10 firms with recordkeeping failures in connection with employees’ use of unapproved applications on personal devices to engage in communications relating to the firms’ business (known as “off-channel communications”).1 The firms charged included broker-dealers, investment advisers, and dually registered broker-dealers and...