New York State has been very aggressive in regulating and sanctioning firms engaged in financial activities. In their original form, the  to regulate "money laundering" set impossible-to-meet compliance standards. (Ultimately, the  were less draconian than those that were proposed originally, but that is saying very little.) The adopted Cybersecurity regulations are open-ended, complex and burdensome and will result in creating many new ways for the government to collect…

The holding in this case serves as a reminder that (i) anyone who exercises day-to-day supervisory authority over the activities of a broker-dealer must be registered as a principal of the broker-dealer and (ii) a legal entity that shares in brokerage commissions generally is required to register as a broker-dealer.

.

Firms should allow sufficient time for putting the technology and processes in place to comply with the new rules, which could be fairly complicated to implement given the need to "match" prices on particular purchases and sales that often will not bear any particular relationship to one another. Markups will be required to be disclosed on certain transactions for which there is deemed to be an offset, but not on similar trades that cannot be matched to a trade on the other side of the…