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New PCAOB Oversight Rules
Two new rules were approved by the SEC on August 18, 2011 related to oversight of the audits of brokers
and dealers and independent public accounting firms by the Public Company Accounting Oversight
Board (PCAOB). ... |
By: Phil Dawicki and Laura Crosby-Brown |
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Private Funds: Who Does Not Have to
Register with the SEC?
Historically, private fund advisers were not required to register with the SEC if they had less than 15 clients (funds). As a result of Title IV of the Dodd-Frank Act, the private adviser exemption has been eliminated. The consequence of this is that previously ... |
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Expense Sharing Agreements and
What Makes Them Tick with FINRA
Over the years, many questions arose as to the use of expense sharing arrangements by broker-dealers.
In 2003, the Securities and Exchange Commission (“the Commission” or “the SEC”) issued guidance
to FINRA in response to its questions on what the SEC ...
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Financial Adviser Placement Agent Registration
Firms that engage in activities pertaining to private placements of municipal securities may be acting in that capacity as a broker, as defined in Section 3(a)(4) of the Exchange Act of 1934 and could be viewed as a placement agent by the MSRB pursuant to guidance recently released in Notice 2011-37... |
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Form ADV Part 1 Changes
Pursuant to a myriad of last-minute amendments made to various rules under the Investment Advisers Act (1940), the Form ADV Part 1 has been revised to include numerous changes. In June, the SEC adopted these amendments to pave the way for those changes wrought by the passage of Title IV of the Dodd-Frank Act... |
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Requirements Under New FINRA Rule 4530
New FINRA Rule 4530, representing a consolidation of NASD Rule 3070 and NYSE Rule 351, took effect July 1, 2011. The new rule incorporates most of the reporting requirements under legacy NASD and SEC Rules 3070 and 351, respectively, and includes changes regarding ... |
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Registration of Operations Professionals-
This Can't Apply to Your Firm...Or Does It?
Requirements to register Operations Professionals begin October 17, 2011 when FINRA’s new Rule 1230(b)(6) becomes effective. What does this mean? How might it apply to anyone in our firm? These
are the questions of the day ... |
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