All Things FinReg

The die is cast: FINRA has published Regulatory Notice 24-02 (RN 24-02) announcing the effective dates and other key dates and considerations for its recently adopted Residential Supervisory Location (RSL) and Remote Inspection Pilot Program (Pilot Program) rulemakings, to be codified as FINRA Rules 3110.19 and 3110.18, respectively. Together, these rules will offer FINRA member firms additional flexibility in how they structure certain aspects of their supervisory system following the sunsetting of related COVID-19 relief.

The House Committee on Financial Services passed the Improving Disclosure for Investors Bill of 2023 on April 26, 2023 with bipartisan support. If passed by Congress and signed into law, the bill could alter the regulatory landscape for electronic delivery (e-delivery) by US Securities and Exchange Commission (SEC) registrants by eliminating the requirement to obtain an investor’s affirmative consent for e-delivery and allowing firms to implement a notice and optout approach to implementing e-delivery.

As many are aware, Congress passed its own version of the US Securities and Exchange Commission (SEC) staff’s mergers and acquisitions (M&A) broker no-action letter in December 2022, creating a new exemption from broker registration in Section 15(b)(13) of the Exchange Act that largely tracks the SEC staff’s no-action letter, with one important tweak.