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SEC Adopts Exchange Act Rules 3a5-4 and 3a44-2 – Dealer Registration Requirements

Summary Overview On February 6th, 2024, the Securities and Exchange Commission (SEC or the Commission) adopted two rules, Exchange Act Rules 3a5-4 and 3a44-2 (the Final Rules), which require market participants who engage in dealer roles, in particular those who take on significant liquidity-providing roles, to (i) register with the SEC, (ii) become a member […]

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CFTC Seeks Comments on AI Usage and Risks in Derivatives Markets

On January 25, 2024, the Commodity Futures Trading Commission (CFTC) issued a request for comment (RFC) on the current and potential uses and risks of artificial intelligence (AI) in the derivatives markets. The RFC follows President Biden’s October 2023 Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (Executive Order), […]

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AML Compliance Continues to be an SEC Priority

On July 31, 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert highlighting observations made by Division staff during recent examinations of broker-dealers concerning anti-money laundering (AML) compliance. The Alert provides insights into areas of focus for future exams and is intended to assist firms in developing or enhancing […]

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FINRA Seeks Comment on its Proposed Liquidity Risk Management Rule

On June 12, 2023, the Financial Industry Regulatory Authority (FINRA) announced that it is seeking comments on a concept proposal for a Liquidity Risk Management rule (Proposed Rule 4610, or Proposal) as a measure purported to ensure that required broker-dealers maintain adequate liquid assets to fulfill their funding requirements under both normal and stressed conditions. […]

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The Risks, Rewards, and Impact of AI Technology on the Financial Services Industry

Artificial Intelligence products are dominating the technology sector. OpenAI and its chatbot, ChatGPT, have made headlines for passing standardized testing, generating complex software code, and helping individuals with tax filings. Microsoft Co-Founder Bill Gates said OpenAI’s developments will be “as revolutionary as mobile phones and the Internet.”[1] ChatGPT has become the fastest platform in the […]