The FDIC and Federal Reserve Board (collectively, the "agencies") found that the resolution plans (the "plans") of four foreign-based banks had "shortcomings" in how each bank communicated and coordinated between its U.S. operators and foreign parent "in stress." Separately, the agencies adopted final resolution plan "guidance for the 2019 and subsequent resolution plan submissions by the eight largest, complex U.S. banking organizations." Pursuant to the Dodd-Frank Act, resolution plans are mandated and must outline a company's strategy for a resolution under bankruptcy "in the event of

FINRA's new Report on Selected Cybersecurity Practices - 2018(the "Report") is one of FINRA's latest initiatives to help broker-dealers further enhance their cybersecurity programs. In the Report, FINRA reviewed how firms are (i) bolstering their cybersecurity controls in branch offices, (ii) limiting phishing attacks, (iii) identifying and alleviating insider threats, (iv) strengthening penetration-testing programs, and (v) creating and maintaining controls on mobile devices. FINRA observed firms instituting the following practices, among others: establishing written supervisory procedures (

The SEC adopted a new rule that would establish a pilot program (the "Pilot") to study the effects that transaction-based fees and rebates in certain National Market System ("NMS") stocks may have on order-routing behavior, execution quality and market quality generally. The Pilot will be applicable to all stock exchanges and will last for up to two years. According to the SEC, the Pilot will create two test groups of exchanges, with one group barred "from offering rebates and linked pricing" and the other group limited to a fee cap of $0.0010. The data from the Pilot will be utilized to

In two newly released reports, SEC staff concluded that nationally recognized statistical rating organizations ("NRSROs") continue to promote compliance with SEC rules and staff examinations. This conclusion is based on the NRSROs' enhanced "policies, procedures, and internal controls." The SEC found that some NRSROs self-reported instances of noncompliance. SEC staff also noted that certain NRSROs were not adhering to their policies and procedures for: determining ratings; Rule 17g-7(a) information disclosures; "surveillance or withdrawals of outstanding ratings"; conflicts of interest, such

The SEC adopted final rules allowing reporting companies to use the Regulation A exemption from registration for their securities offerings. The final rules amend Securities Act Rule 251 to permit companies subject to the Exchange Act Section 13 or 15(d) reporting requirements to use the exemption provided by Regulation A. The final rules also revise Securities Act Rule 257 to provide that companies satisfying the reporting requirements of the Exchange Act have met the Regulation A reporting requirements. In addition, the SEC made other conforming changes to Regulation A and Form 1-A. The