Finance Law and Banking Law

The SEC has approved FINRA's consolidated Rule 3290, which will replace existing outside-activities rules for broker-dealer employees. While approval marks a regulatory milestone, firms must distinguish it from effectiveness and use the transition period strategically to rebuild disclosure forms, risk assessment frameworks, supervisory conditions, and compliance records before the rule takes effect.

On September 17, 2026, the CFTC's Market Participants Division issued a no-action position for providers of passive derivatives-trading software, establishing a framework under which certain front-end applications may operate without introducing-broker registration. The relief depends on ten specific conditions covering disclosures, liability undertakings, compliance procedures, and operational constraints that distinguish passive market access from solicitation. Product teams and compliance officers must u

When a bank restructures a classified asset, does it automatically lose its low-quality status under Regulation W? This analysis examines the strict requirements for removing low-quality asset designations and the critical role of independent examiner re-classification in determining whether banks can purchase restructured assets from affiliates.