Upcoming FINRA Board of Governors Election

June 5, 2019
Volume 23
 
 
guidance

Guidance
  • Regulatory Notice
upcoming

Upcoming Deadlines and Effective Dates
  • FINRA Requests for Comment
  • FINRA Elections
education

Education and Compliance Programs


Treasury calls for large position reports. On June 3, 2019, the U.S. Department of the Treasury announced a call for Large Position Reports from those entities whose positions in the 2-1/4% Treasury Notes of April 2024 equaled or exceeded $4.1 billion as of Tuesday, April 30, 2019 and/or Friday, May 3, 2019. Treasury’s large position reporting rules (17 CFR Part 420) provide an on-demand reporting system that requires large position reports to be filed by entities that control a position in a particular Treasury security (or securities) equaling or exceeding the specified large position thresholds. Such information allows Treasury to monitor the impact of concentrations of positions in the Treasury securities market. Supplementary formula guidance to Treasury’s Large Position Rules is available on the TreasuryDirect website.
 



FINRA reminds firms to register for CAT reporting by June 27, 2019. FINRA issued Regulatory Notice 19-19 to remind firms they must register with FINRA CAT, LLC (FINRA CAT) for reporting to the Consolidated Audit Trail (CAT). CAT registration commenced on March 18, 2019, and will run through June 27, 2019. All Industry Members, as defined under the CAT NMS Plan, that will have a CAT reporting obligation must register during this window.

All questions regarding CAT registration should be directed to the FINRA CAT Helpdesk at (888) 696-3348 or [email protected].

 

 Guidance

SEC Approves Amendments to Arbitration Codes to Expand Time for Non-Parties to Respond to Arbitration Subpoenas and Orders of Appearance of Witnesses or Production of Documents

The Securities and Exchange Commission (SEC) approved amendments to FINRA’s customer and industry arbitration rules to expand time for non-parties to respond to arbitration subpoenas and orders of appearance of witnesses or production of documents. The amendments also make related changes to enhance the discovery process for forum users. The amendments, outlined in Regulatory Notice 19-20, are effective for cases filed on or after July 1, 2019.
 

 Upcoming Deadlines and Effective Dates

FINRA Requests for Comment

FINRA has issued Regulatory Notice 19-12 to request comment on a proposed pilot program to study changes to corporate bond block trade dissemination based on recommendations of the SEC Fixed Income Market Structure Advisory Committee (FIMSAC). Specifically, the proposed pilot is designed to study two primary changes recommended by the FIMSAC: an increase to the current dissemination caps for corporate bond trades, and delayed dissemination of any information about trades above the proposed dissemination caps for 48 hours. The proposed pilot incorporates these primary elements of the FIMSAC Recommendation and other features, including a control group, designed to support a meaningful analysis of the pilot’s impact. Comments are due June 11, 2019.

As part of FINRA’s ongoing initiatives to protect investors from misconduct, FINRA has issued Regulatory Notice 19-17 to request comment on proposed new Rule 4111 (Restricted Firm Obligations) that would impose tailored obligations, including possible financial requirements, on designated member firms that cross specified numeric disclosure-event thresholds. These thresholds were developed through a thorough analysis and are based on the number of events at similarly sized peers. The member firms that could be subject to these obligations, while small in number, present heightened risk of harm to investors and their activities may undermine confidence in the securities markets as a whole. The proposal would further promote investor protection and market integrity and give FINRA another tool to incentivize member firms to comply with regulatory requirements and to pay arbitration awards.
Comments are due July 1, 2019.


FINRA Elections

The annual meeting of FINRA firms will take place on or about Monday, August 19, 2019, to elect one Large Firm Governor and one Small Firm Governor to the FINRA Board of Governors. A formal notice of the meeting, including the precise date, time and location, will be mailed to executive representatives on or about July 19, 2019. The purpose of Election Notice 5/24/19 is to notify FINRA members of the FINRA Nominating Committee’s nominees to fill these vacancies and inform individuals not nominated by the Nominating Committee of the petition procedures set forth in FINRA’s By-Laws for being included on the ballot for these elections. Petitions must be submitted no later than Monday, July 8, 2019.
 

 Education and Compliance Programs

Register today for the 2019 National Compliance Outreach Program for Broker-Dealers. The program, sponsored by FINRA and the SEC, is designed to provide an open forum for regulators and industry professionals to discuss current compliance practices and promote an effective compliance structure for the protection of investors. The event will be held on June 27, 2019, in Chicago, IL. Download the full agenda. Participate in person or via live video webcast.


FINRA is hosting several upcoming Half-Day Compliance Boot Camps, AML Half-Day Seminars and Cybersecurity Half-Day Seminars across the country.

Half-Day Compliance Boot Camps

  • July 16, 2019 | Boca Raton, FL
  • August 8, 2019 | Del Mar, CA
  • September 17, 2019 | Minneapolis, MN
  • September 17, 2019 | Stamford, CT

AML Half-Day Seminars

  • September 19, 2019 | Chicago, IL

Cybersecurity Half-Day Seminars

  • August 27, 2019 | Costa Mesa, CA
  • September 26, 2019 | Boca Raton, FL

District compliance events are designed for compliance and legal professionals at FINRA member firms, and offer an opportunity to hear about current regulatory issues while engaging with District Office staff. Upcoming events will be held in the Boston, Los Angeles, Woodbridge and Atlanta District Offices.

Review the compliance calendar to see a complete list of events.


Register today for the 2019 Small Firm Conference, which takes place October 23-24, in Santa Monica, CA. This two-day event brings together FINRA staff and industry peers for in-depth discussions on small firms' practices.


Registration is now open for the 2020 FINRA Annual Conference—which takes place May 12–14 in Washington, DC. Join leaders of firms of all sizes, compliance professionals, securities attorneys, government officials, FINRA senior leaders and representatives from other securities regulators for a three-day event dedicated to the most important issues affecting the securities industry.

Reduced rates are available for the first 100 in-person registrants through October 4, 2019. Register today.


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