On 18 November 2021, the Securities and Exchange Commission (“SEC”) published for comment proposed amendments to the broker-dealer recordkeeping rules with respect to the use of electronic storage. The principal change would be to eliminate the current requirement that electronic records of broker-dealers be stored solely in a “write once, read many” (WORM) format.
The SEC Division of Examinations (Exams) recently published a Risk Alert discussing observations on investment adviser fee calculations resulting from a review of approximately 130 firms. This 2021 Risk Alert supplements a prior alert on the same topic that Exams (then, the Office of Compliance Inspections and Examinations) published in 2018.
As reported earlier, the Ukrainian Parliament is now scrutinzing a draft law, which will replace the current general financial services framework (Draft Law). Back in March 2021, we assessed the key features of the revised regulatory regime. For this article, we will focus on one of the key topics specifically relevant for any financial institution (FI) – whether its activity may be viewed as a provision of services in a foreign jurisdiction (in our case in Ukraine) and thus, subject to local regulatory approval.
The Securities and Futures Commission (SFC) recently released its Consultation Conclusions on Proposed Enhancements to the Competency Framework for Intermediaries and Individual Practitioners. The changes to the existing Guidelines on Competence (Competence Guidelines) and Guidelines on Continuous Professional Training (CPT Guidelines) (together the “Guidelines”) will take effect in January 2022.
Baker McKenzie’s Financial Services Global Regulatory (FSR) Guide acts as a quick reference tool when distributing financial products into new markets, providing a comprehensive summary of regulations applicable to banks and other financial services companies around the world.
In yet another step forward on the SEC’s path toward a comprehensive ESG disclosure framework, on September 22, 2021, the Staff of the Division of Corporation Finance issued a Sample Letter to Companies on Climate Change Disclosure, relying on the Commission’s 2010 Climate Change Guidance.