This CFTC no-action letter provides long-awaited relief from CTA registration for family offices by addressing the regulatory gap left by CFTC Letter 12-37, which provided them with CPO – but not CTA – registration relief. The latest letter rounds out the "exempt" status of family offices, which are excluded from investment adviser registration with the SEC pursuant to Rule 202(a)(11)(G)-1 under the Advisers Act, and which may claim CPO and CTA registration relief pursuant to CFTC No-Action…

This is a significant enforcement action in terms of both the severity of the fine imposed on Citi by FINRA and the lessons to be learned by other firms, as discussed below. Firms should consider these issues in light of the proposed new debt and equity research rules that FINRA filed with the SEC last week, which place an overarching obligation on firms to adopt and implement written policies and procedures to "identify and effectively manage conflicts of interest" arising from firms'…

Given that every regulatory scheme has an (anti-) pay-to-play rule, the question is not whether these rules will be adopted; it is, rather, whether there will be any discrepancies between these rules and similar rules that may operate as a trap for the unwary.

FINRA's debt research rule filing follows a concept proposal (FINRA Reg. Notice 11-11) and two previous debt research rule proposals (FINRA Reg. Notices 12-09 and 12-42). Firms should begin considering how they would go about incorporating the requirements of the proposed rule into their research policies and procedures. As a threshold question, firms should consider the categories of research they produce (e.g., equity, debt, derivatives or macro). While some types of research reports fall…