Financial Services Observer

News & Commentary on Financial Regulatory and Compliance Matters

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Financial Services Observer

FINRA’s 2020 Risk Monitoring and Examination Priorities Letter

By William Mack & Jennifer D. Newton

January 17, 2020

On Jan. 9, 2020, the Financial Industry Regulatory Authority (FINRA) released its 2020 Risk Monitoring and Examination Priorities Letter, in which it identifies its areas of examination focus for 2020. The cover note also highlights key changes in FINRA’s risk monitoring and examination program. These changes include the consolidation of FINRA’s three examination programs into a single risk monitoring framework. As part of this new framework, FINRA expects to categorize every FINRA member firm…

Financial Services Observer

SEC Publishes OCIE 2020 Examination Priorities

By Richard M. Cutshall

January 9, 2020

On Jan. 7, the SEC announced the publication of the annual Office of Compliance Inspections and Examinations (OCIE) 2020 Examination Priorities. In addition to the examination priorities themselves, the 28-page publication includes statistics related to OCIE’s 2019 examination program, touting OCIE’s completion of over 3,000 examinations covering ~15% of registered investment advisers and verification of 31 million investor accounts aggregating over $1.5 trillion in fiscal year 2019. The examination priorities themselves are a mix of…

Financial Services Observer

New York State Department of Financial Services Proposes Guidance on Adoption or Listing of Virtual Currencies by Exchanges

By William Mack, Barbara A. Jones, Michele L. Kulerman & India L. Sneed

December 30, 2019

In the summer of 2015, the New York State Department of Financial Services (DFS) finalized its regulatory framework for virtual currency firms seeking to conduct certain virtual currency (VC) business activities in the state. Since then, it has issued two dozen licenses and charters involving virtual currency transmission (VC licenses). To promote efficiency and reflect the growing marketplace, DFS has now issued two proposals for which comments are due Jan. 27, 2020. The first proposal…

Financial Services Observer

LIBOR Transition Newsletter – Issue 2

By Oscar Stephens, Sylvie A. Durham, Arleen A. Nand & Graeme McLellan

December 19, 2019

Welcome to the second issue of Greenberg Traurig’s LIBOR Transition Newsletter, which contains updates, analysis, and commentary on the latest developments relating to the highly anticipated phasing-out of LIBOR at the end of 2021 – barely two years from now. This issue covers the following: LSTA – Concept SOFR Credit Agreement Recent Developments Parting Shot – What if Someone Finds the Proposed LIBOR Replacement Fallback Language “Too Long”? Read the full LIBOR Transition newsletter – …

Financial Services Observer

SEC Proposes Conditional Exemption for Certain Activities of Registered Municipal Advisors

By Elaine C. Greenberg, William Mack & Vincent Lewis

December 18, 2019

Section 15 (a)(1) of the Securities Exchange Act of 1934 (Exchange Act) generally prohibits a broker or dealer from effecting “any transactions in, or to induce or attempt to induce the purchase or sale of, any security” unless such broker or dealer is registered with the Securities and Exchange Commission (SEC). However, as is often the case in U.S. securities laws, the requirements of Section 15(a)(1) are subject to exceptions. On Oct. 2, 2019, the…

Financial Services Observer

LIBOR Transition Newsletter – Issue 1

By Oscar Stephens, Sylvie A. Durham, Arleen A. Nand & Graeme McLellan

November 6, 2019

Welcome to Greenberg Traurig’s LIBOR Transition Newsletter, where we provide updates, analysis, and occasional commentary on the latest developments relating to the highly anticipated phasing-out of LIBOR at the end of 2021 – barely two years from now. Questions addressed in this issue: Why is LIBOR being phased out? What will be the immediate effect? Where are we now? Are market participants ready for LIBOR replacement? What should market participants be doing now? Documentation and…

Financial Services Observer

2019 Report on FINRA Examination Findings and Observations

By Richard M. Cutshall, William Mack & Vincent Lewis

October 30, 2019

In October 2019, the Financial Industry Regulatory Authority (FINRA) released its “2019 Report on FINRA Examination Findings and Observations.” FINRA publishes a report yearly to highlight its examination “findings” (i.e., findings of violations committed by member firms) detected throughout the year. In addition to findings, the 2019 Report advances further than years past and consists of “observations.” Observations (formerly known as recommendations) are suggestions to a member firm on how to improve its…

Financial Services Observer

U.S. House Passes Bill That Would Require Disclosure of Beneficial Owners of U.S. Corporations and Limited Liability Companies

By Carl A. Fornaris, Marina Olman-Pal & Anthony J. Fernandez

October 29, 2019

On Oct. 22, 2019, the U.S. House of Representatives, in a 249 to 173 vote, passed H.R. 2513, known as the “Corporate Transparency Act of 2019.” The Corporate Transparency Act, if enacted into law, would require each person who creates a corporation or limited liability company in the United States to report, on an ongoing basis, to the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) the identities of the “beneficial owners”…

Financial Services Observer

CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act

By Carl A. Fornaris, Marina Olman-Pal & Anthony J. Fernandez

October 23, 2019

On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on Activities Involving Digital Assets. The purpose of the Joint Statement was “to remind persons engaged in activities involving digital assets of their anti-money laundering and countering the financing of terrorism (AML/CFT) obligations under the Bank Secrecy Act (BSA).” Click here for the full GT …

Financial Services Observer

Bermuda Launches Two Key Fintech Initiatives, Becomes First Nation to Accept Stable Coins for Government Payments

By Barbara A. Jones

October 22, 2019

On Oct. 16, 2019, Bermuda Premier the Hon. E. David Burt JP, MP announced that Bermuda has committed to accept, for payment of government taxes, fees, and services, 1:1 U.S.-dollar-backed digital currencies of entities licensed by the Bermuda Monetary Authority (BMA) under the 2018 Digital Asset Business Act (DABA), becoming the first nation to do so. Known for its established skill in regulating financial services, particularly in the insurance and re-insurance markets, Bermuda has in…

Financial Services Observer

News & Commentary on Financial Regulatory and Compliance Matters

Blog Authors

FINRA’s 2020 Risk Monitoring and Examination Priorities Letter

SEC Publishes OCIE 2020 Examination Priorities

New York State Department of Financial Services Proposes Guidance on Adoption or Listing of Virtual Currencies by Exchanges

LIBOR Transition Newsletter – Issue 2

SEC Proposes Conditional Exemption for Certain Activities of Registered Municipal Advisors

LIBOR Transition Newsletter – Issue 1

2019 Report on FINRA Examination Findings and Observations

U.S. House Passes Bill That Would Require Disclosure of Beneficial Owners of U.S. Corporations and Limited Liability Companies

CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act

Bermuda Launches Two Key Fintech Initiatives, Becomes First Nation to Accept Stable Coins for Government Payments

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