William J. Barbera

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Articles

New AML Requirements For Investment Advisers: Lessons From Recent Enforcement Actions

2 weeks ago | mondaq.com | Melissa Goldstein |Betty Santangelo |John Nowak |William J. Barbera

As investment advisers prepare to comply with the new anti-moneylaundering ("AML") program and reporting requirementseffective Jan. 1, 2026, it is instructive to review recentenforcement actions brought by the Securities and ExchangeCommission ("SEC").
SEC's Dealer Rule Vacated

Nov 28, 2024 | mondaq.com | William J. Barbera |Julian Rainero |Derek N. Lacarrubba |Kristopher J. Kendall

On Nov.
UK Compliance Update: FCA Rules Will Allow CSA-Style Payments For Research From 1 Aug. 2024

Jul 31, 2024 | mondaq.com | Anna Maleva-Otto |William J. Barbera

The UK Financial Conduct Authority ("FCA") has released the final rules on the Payment Optionality for Investment Research in its PS 24/9.1 The FCA rules refer to this new research payment structure as "joint payments for third-party research and execution services"; in fact, it is based on a commission sharing arrangement ("CSA Option") combined with detailed procedural and operational safeguards, including budgeting, valuation and client disclosure obligations.
Private Fund Managers Alert: New Filing Deadlines And Current Regulatory Focus Areas

Jul 1, 2024 | mondaq.com | Christopher S. Avellaneda |William J. Barbera |Allison Bernbach |Michael Didiuk

SR Schulte Roth & Zabel LLP More With a firm focus on private capital, Schulte Roth & Zabel comprises legal advisers and commercial problem-solvers who combine exceptional experience, industry insight, integrated intelligence and commercial creativity to help clients raise and invest assets and protect and expand their businesses.
SEC Adopts Information Security And Notification Amendments To Regulation S-P

Jun 14, 2024 | mondaq.com | William J. Barbera |Kelly Koscuiszka |Philip J. Bezanson |Tarik M. Shah

On May 16, 2024, the Securities and Exchange Commission ("SEC") announced that it had adopted amendments ("Amendments")1 to Regulation S-P ("Reg S-P")2. The SEC explained that the Amendments represent an effort to "modernize and enhance" rules designed to protect consumers' nonpublic information and privacy.
SEC Targets Certain Proprietary Trading Firms And Private Funds With Expanded

Feb 29, 2024 | mondaq.com | William J. Barbera |Jennifer Dunn |Marc E. Elovitz |Kelly Koscuiszka

On Feb. 6, 2024, the US Securities and Exchange Commission ("SEC" or "Commission") adopted new Rules 3a5‑4 and 3a44‑2 (together, "Final Rules")1 under the Exchange Act to further define what it means to be "engaged in the business" of buying and selling securities for one's own account and, as such, required to register with the SEC as a "dealer" or "government securities dealer," as applicable (collectively, a "Dealer").
Information Leakage

Nov 10, 2023 | mondaq.com | Marc E. Elovitz |Julian Rainero |William J. Barbera |Derek N. Lacarrubba

On Oct. 13, 2023, the SEC adopted new Rule 10c-1a under the Securities Exchange Act of 1934, as amended ("Exchange Act"), which the Federal Register officially published on Nov.
SEC Expands FINRA Oversight Of Proprietary Trading Firms

Sep 7, 2023 | mondaq.com | Julian Rainero |William J. Barbera |Derek N. Lacarrubba |Kristopher J. Kendall

On Aug. 23, 2023, the US Securities and Exchange Commission ("Commission") adopted amendments1 ("Amendments") to the Securities Exchange Act of 1934 ("Exchange Act") to require certain SEC-registered dealers that were previously exempt from national securities association2 membership to register with the Financial Industry Regulatory Authority ("FINRA").
SEC Expands FINRA Oversight of Proprietary Trading Firms

Sep 6, 2023 | lexology.com | Julian Rainero |William J. Barbera |Derek N. Lacarrubba |Kristopher J. Kendall

On Aug. 23, 2023, the US Securities and Exchange Commission (“Commission”) adopted amendments[1] (“Amendments”) to the Securities Exchange Act of 1934 (“Exchange Act”) to require certain SEC-registered dealers that were previously exempt from national securities association[2] membership to register with the Financial Industry Regulatory Authority (“FINRA”).