SEC Outlines Path to Digital Asset Custody for Broker-Dealers

On December 23, 2020, the SEC issued a request for comment regarding the application of the Customer Protection Rule to digital asset securities. With the request for comment, the SEC also issued a statement indicating that, if a broker-dealer operates under specific circumstances set out in the statement, it would not seek enforcement action on… READ MORE

5 Things to Know about Remote Branch Inspections

In a much-anticipated notice, FINRA announced the implementation of the temporary guidance allowing firms the ability to conduct branch office inspections on a remote basis. While this is a big relief for compliance officers wondering how they were going to complete branch inspections in a period of safety concerns and social distancing, it is important… READ MORE

5 Things to Know About NASAA’s Model Rules

NASAA published two model rules in November 2020 related to continuing education requirements and written policies and procedures. While each state determines whether to adopt model rules, you should familiarize yourself with the requirements, not just so you can comply, but because some of the requirements are just good business practices. Get ready for more… READ MORE

CAT Participants Seek Exemptive Relief

On December 4, 2020 CAT Plan Participants submitted two exemptive relief requests to the Securities and Exchange Commission (SEC): A request for exemptive relief from certain provisions of the CAT NMS Plan related to initial data validation, lifecycle linkages and communication of errors by T+1 at 12:00pm ET In this request the CAT Plan Participants… READ MORE

Repairing CAT Accepted Late Trades

In FINRA’s Notice to Members 20-31, members are asked to consider incorporating into their Consolidated Audit Trail (CAT) supervisory system “Daily review of the CAT Reporter Portal to: identify late trades.” While the FINRA CAT portal provides a count of events which were “Accepted Late,” it does not identify what constitutes an Accepted Late trade…. READ MORE

Early CAT Reporting Struggles Lead to Improved Error Rates

Compliance for the Firm-to-Firm/Exchange/TRF linkage implementation phase of Consolidated Audit Trail (CAT) reporting came into effect October 26, 2020.  In the weeks leading up to this there were significant concerns around how the industry would be able to bring error rates down to an acceptable level after the initial rejections rate, in some cases, soared… READ MORE