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The successor to a former dually registered investment adviser and broker-dealer agreed to settle SEC charges relating to misleading advisory clients about the cost of its in-house brokerage services. As alleged in the SEC Order, Valley Forge Asset Management, LLC ("Valley Forge") led clients to believe that its affiliated broker charged lower rates than were available elsewhere, even though the broker sometimes actually charged commissions that were over four times more than clients would have paid using alternative brokerage options. The Order also found that Valley Forge benefited from its

A financial services firm agreed to settle FINRA charges for Regulation SHO ( i.e., short sale rule) violations. According to the Letter of Acceptance, Waiver and Consent, the firm, among other things: failed to close out certain "fail-to-deliver" ("FTD") positions from short sales, as required by Rule 204(a), in a timely manner; improperly routed and executed short sale orders by failing first to borrow or to arrange to borrow securities, as required by Rule 204(b); neglected to provide notice - as required by Rule 204(c) - to other broker-dealers for whom the firm cleared and settled trades

Steven Lofchie Commentary by Steven Lofchie

An SEC-registered broker-dealer and FINRA member agreed to settle FINRA charges for failing to properly or timely submit 366,428 Reportable Order Events ("ROEs") in one quarter to the Order Audit Trail System ("OATS"), and 58,365 ROEs during a four-month period in the same calendar year, in violation of FINRA Rule 7450 ("Order Data Transmission Requirements"). According to the Letter of Acceptance, Waiver and Consent, Great Point Capital LLC agreed to a censure and to pay $20,000 to settle the charges.

Commentary by Nihal Patel

The Basel Committee on Banking Supervision and IOSCO ("BCBS-IOSCO") issued a statement on the implementation of derivatives margin requirements related to (i) benchmark reforms and (ii) initial margin thresholds. In the statement, BCBS-IOSCO indicates that amendments to "legacy" derivatives contracts "solely for the purpose of addressing interest rate benchmark reforms" do not bring trades into scope for relevant margin requirements. However, BCBS-IOSCO cautions that positions may be different under relevant implementing laws. In the statement, BCBS-IOSCO also addresses the 2019-2020 phased

FDIC General Counsel Charles Yi will leave the agency at the end of March. He has served in the role since January 2015. As General Counsel, Mr. Yi was involved in rulemakings, enforcement actions and litigation.