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SEC Senior Financial Economist Audra L. Boone and Assistant Professors Kathryn Schumann and Joshua T. White investigated the frequency and content of information supplied by foreign firms through SEC Form 6-K disclosure requirements. In a research paper titled "The Information Content and Investor Reaction to SEC Disclosures by Foreign Firms," the authors found significant differences between the disclosure requirements for foreign firms and those for domestic firms. Under foreign firm disclosure requirements, management has more discretion. The authors stressed the importance of the SEC's

FINRA released a podcast that summarized its latest notices, compliance resources and news from October 2015. The podcast covers the following recent developments: Requests for Comment FINRA requested comments, to be submitted no later than November 13, 2015, on a revised proposal requiring the confirmation disclosure of pricing information in corporate and agency-debt securities transactions (FINRA Reg. Notice 15-36). FINRA requested comments, to be submitted no later than November 30, 2015, on two rules concerning the financial exploitation of seniors and other vulnerable adults (FINRA Reg

Steven Lofchie Commentary by Steven Lofchie

In a letter to the SEC, the Futures Industry Association Principal Traders Group ("FIA") suggested changes regarding the application by the Investors' Exchange, LLC ("IEX") for registration as a National Securities Exchange. The letter referenced three specific concerns about IEX's application, including: (i) IEX's proposal to give protected status to its quotes despite their being subject to an intentional access delay; (ii) the introduction of pegged order types with a speed advantage over other order types; and (iii) IEX's affiliated broker-dealer not being subject to the access delay in

Steven Lofchie Commentary by Steven Lofchie

SEC approval of amendments to FINRA Rule 8312 ("FINRA BrokerCheck Disclosure") was published in the Federal Register. Under the rule change, the fifteen-day waiting period for the release of negative information on Form U5 through BrokerCheck will be reduced to three days. The purpose of the reduction is to expedite public disclosures of any negative information about a broker-dealer employee.

FINRA's proposal to adopt FINRA Rule 4380, related to mandatory participation in business continuity and disaster recovery, was published for comment in the Federal Register. Proposed Rule 4380(a) would designate members whom FINRA has reasonably determined to reach the minimum number required for the maintenance of "fair and orderly" markets in the event of the activation of its BC/DR plan. Proposed Rule 4380(b) would reiterate several "important points" from Regulation SCI with respect to BC/DR plan testing. Revised Rule 4380(c) also would state the obligations of member firms that are