TO: All NASD Members and Other Interested Persons
It has come to the NASD's attention that some members are engaging in a practice whereby market making or wholesale dealers pay retail firms to direct those firms' customer orders to the market maker. The Board of Governors has established a special subcommittee of the National Business Conduct Committee to study potential problems
IMPORTANT
TO: All NASD Members and Other Interested Persons
Over the past several months, some questions have arisen relating to members' procedures when executing transactions for their own accounts while in possession of unexecuted customer limit orders for over-the-counter securities. In May 1984, the NASD Board of Governors appointed an Ad Hoc Committee on Limit Orders to review members
FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
(a) Filing Requirements
Each member that sells a security in a non-public offering in reliance on an available exemption from registration under the Securities Act ("private placement") must: (i) submit to FINRA, or have submitted on its behalf by a designated member, a copy of any private placement memorandum, term sheet or other offering document, and any retail communication (as
FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
INFORMATIONAL
Continuing Education
SUGGESTED ROUTING
KEY TOPICS
Continuing Education Testing/Qualifications
Legal & Compliance
Senior Management
Continuing Education
Firm Element
The Suggested Routing function is meant to aid the reader of this document. Each NASD member firm should consider the appropriate distribution in the context of its own organizational structure.
The Trusted Contact Persons section of the 2023 Report on FINRA’s Examination and Risk Monitoring Program (the Report) informs member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations, including (1) regulatory obligations and related considerations, (2) findings and effective practices, and (3) additional resources.
NASD Rule 2510 - Discretionary Accounts - A member may use the negative response process under Rule 2510(d)(2)(A) to effectuate the transfer to another money market fund of customer free credit balances that have been returned to the member by a fund that has been terminated.
INFORMATIONAL
SUGGESTED ROUTING
KEY TOPICS
Legal/Compliance Retail Senior Management
Hedge Funds Funds of Hedge Funds Suitability Due Diligence Internal Controls Supervision Training
Executive Summary
As a result of a recent review of members that sell hedge funds and registered products (closed-end funds) that invest in hedge funds ("funds of hedge funds"),
Summary
To bring attention to a rising trend in the fraudulent transfer of customer accounts through the Automated Customer Account Transfer Service (ACATS), FINRA issued Regulatory Notice 22-21, which alerted member firms about how bad actors effect fraudulent transfers of customer assets using ACATS (referred to as ACATS fraud). That Notice listed several existing regulatory obligations that
