ARTICLE
11 February 2019

Trade Association Highlights Challenges Of Order Handling Disclosures

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Financial Information Forum ("FIF") highlighted several challenges and questions regarding amendments to Regulation NMS Rule 606(b),.
United States Corporate/Commercial Law

The Financial Information Forum ("FIF") highlighted several challenges and questions regarding amendments to Regulation NMS Rule 606(b), which require broker-dealers ("BDs") to generate on-demand customer reports regarding the order handling of customers' orders, including a "standardized set of individual disclosures."

In a letter to the SEC, the FIF identified challenges that BDs will have in meeting the May 20, 2019 compliance date, including requiring introducing brokers to "obtain and report downstream order execution data." The FIF asserted that many of the requirements may call for BDs to "undergo significant operational, business and technological changes." The FIF also stated that there is significant industry uncertainty regarding the scope of the amendment, and recommended that the SEC clarify a number of key definitions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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