FINRA proposed a rule change to make "substantive, organizational and terminology" amendments to Rule 5110 in order to ensure that underwriters' fees are fair and reasonable. Rule 5110 requires broker-dealers that participate in SEC-registered offerings of securities to file specified documents with FINRA regarding underwriting terms and arrangements. According to FINRA, the proposal is intended to (i) modernize Rule 5110, (ii) simplify and clarify its provisions, and (iii) maintain protections for issuers and investors that participate in public offerings. Specifically, FINRA is proposing the

The SEC Office of Compliance Inspections and Examinations ("OCIE") alerted investment advisers to the most recurrent compliance issues related to the Cash Solicitation Rule (the "rule"). The rule generally prohibits an investment adviser from paying a cash fee to any person who solicits clients for the adviser unless the arrangement complies with various conditions. In its Risk Alert, the OCIE stated that it observed advisers: with third-party solicitors that did not provide solicitor disclosure documents to prospective clients or supply inadequate disclosures; that did not, in a timely manner

The SEC proposed rules and form amendments to improve disclosures to investors in variable annuities and variable life insurance contracts ("variable contracts"). Specifically, the SEC proposed a rule that would allow an issuer to satisfy its prospectus delivery requirement for variable contracts by delivering a summary prospectus. According to the SEC, the new summary prospectus - using a "layered disclosure approach" - would be a reader-friendly overview of critical facts, with information about how to find a more in-depth discussion online or in paper format. The SEC said that the proposed

Staff members of the CFTC Office of the Chief Economist concluded that Phase 5 of the initial margin regime implementation will capture a substantial number of entities with a relatively low average aggregate notional amount ("AANA") of swaps, and with a high proportion of physically settled FX swaps. The economists prepared the newly released paper as a guide for regulators as they respond to requests for relief by market participants who had argued that Phase 5 (which goes into effect on September 1, 2020) would bring a substantial number of relatively small market participants into scope

The CFTC Division of Swap Dealer and Intermediary Oversight (the "Division") granted relief from the requirements of CFTC Rule 30.7 to a futures commission merchant ("FCM") and an investment firm incorporated under the laws of England and Wales, and which is a member of the principal central counterparties ("CCPs") authorized under the European Market Infrastructure Regulation. The relief allows the FCM to deposit customer-owned securities with the investment firm to margin such customers' foreign futures or foreign options positions executed on a foreign board of trade located in the United