March 2011

Third Party Service Providers – Regulatory Notice 11-14

In March 2011, FINRA issued Regulatory Notice 11-14, requesting comments on proposed new rule 3190 clarifying the scope of a member firm’s obligations and supervisory responsibilities for functions or activities outsourced to a third-party service provider. FINRA Rule 3190 clarifies that: Outsourced functions of a broker-dealer to a third-party service provider does not relieve the firm of …

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FINRA Proposes Rules on Debt Research Reports – Regulatory Notice 11-11

In March 2011, FINRA issued Regulatory Notice 11-11 requesting comments on a concept proposal to apply objectivity safeguards and disclosure requirements to the publication and distribution of debt research reports. The proposal would provide retail debt research recipients with most of the same protections provided to recipients of equity research, while exempting research provided solely to institutional …

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SEC Proposes Rules on Disclosure of Incentive-Based Compensation Arrangements at Financial Institutions

On March 2, 2011, the Securities and Exchange Commission proposed rules to require certain financial institutions, broker-dealers and investment advisers with $1 billion or more in assets, to disclose their incentive-based compensation practices and prohibit such institutions from having compensation arrangements that encourage inappropriate risks. Proposed Rules 1) Disclosures about Incentive-Based Compensation Arrangements Annual Filing with appropriate …

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