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February 14, 2022

FINRA Issues Annual Guidance Regarding Compliance Programs

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On February 9, 2022, FINRA published the eagerly awaited 2022 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”). The purpose of the Report is to provide firms with information concerning recent examination findings, outline effective practices observed by FINRA during their exams and generally highlight key considerations for firms’ compliance programs. At a […]

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Necessary Controls to Risk-Manage Cross-Border Trading Practices within FX

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On January 27, 2022, the Hong Kong Securities and Futures Commission (SFC) and the Australian Securities and Investments Commission (ASIC) jointly released a circular that detailed their observations following a collaborative thematic review into the governance arrangements and internal controls within the FX business of selected SFC and ASIC licensed firms. The review covered a

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FINRA Issues Notice Regarding the Proper Handling of Marketable Customer Orders

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On January 21, 2022, FINRA issued Regulatory Notice 22-04 reminding broker-dealers of the requirements under Rule 5310.01 to execute marketable customer orders fully and promptly.  The definition of what “prompt” means has never been clearly delineated in the rule itself although industry practice, based upon the timing requirements of other order handling-type rules, has been

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