Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

Elizabeth J. Hogan

Photo of Elizabeth J. Hogan Elizabeth Hogan (“Lizzie”) is co-chair of the firm’s Securities Enforcement & Regulatory Counseling practice group. As the former senior vice president and leader of Market Regulation Enforcement at the Financial Industry Regulatory Authority (FINRA), Lizzie has unique insight into the priorities and procedures of financial services regulators, including the SEC, FINRA, the exchanges, and state securities regulators and attorneys general. Lizzie represents clients in complex securities matters, focusing on investigations, regulatory enforcement proceedings, and litigation.

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Spring Has Sprung for Recent Reg NMS Reporting Changes

Compliance, Financial Institution Regulation, Securities and Commodities
On March 6, the SEC released its long-anticipated adopting release amending Rule 605.[1]  Separately, in late February, FINRA issued Regulatory Notice 24-05 discussing new FINRA Rule 6151, which requires member firms to provide Rule 606 reports to FINRA. The following provides a brief overview of these recent moves by both regulators.   … Continue Reading

OCIE Finds Supervision Failures at Multiple-Branch Office Investment Advisers

Compliance, Financial Institution Regulation, Securities and Commodities
On November 9, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced the results of its examination of nearly 40 SEC-registered investment advisers that operate multiple branch offices (the “Risk Alert”). Most of the firms examined conducted their advisory business out of at least 10 branch offices. OCIE observed a wide range of… Continue Reading

Yet Another Mutual Fund Fee Issue or “Death by a Thousand Cuts”: FINRA Sweep of Rights of Reinstatement Waivers

Financial Institution Regulation, Securities and Commodities
What is the Issue? It may not be “death by a thousand cuts” but it may feel like it, as yet another mutual fund fee issue is being raised by the regulators. FINRA issued a “targeted examination letter” focused on Rights of Reinstatement (“RoR”) due to customers in certain mutual fund sales and purchases. RoRs… Continue Reading

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