We use cookies to give you the best online experience. By using our website you agree to our use of cookies in accordance with our cookie policy. Learn more here.Close Me
At FINRA's recently
held Annual Conference, Grace Vogel, FINRA Executive Vice
President, was asked about the status of Proposed Rule
3190 regarding the regulation of third-party
service providers, including, without limitation, heightened
supervisory requirements for clearing and carrying firms. She
responded that FINRA had received a wide array of detailed comment
letters from interested parties, all of which are published on FINRA's
website. The comment period ended May 13,
2011. (We provided a summary of the proposed rule in our April 2011 Outsourcing
Alert.)
In an exclusive interview this week with Loeb & Loeb's
Stephen
Cohen, Ms. Vogel confirmed that FINRA has now
completed its review of the comments and is currently preparing its
response for submission to the SEC at which time the industry will
again have an opportunity to comment on the proposed rule once it
is published.
Ms. Vogel had just returned from her meeting with Marc
Menchel, Executive Vice President and General Counsel for FINRA,
and his staff on Monday to discuss the comment letters. She
shared with Loeb & Loeb that, as a result of its review of the
comments, FINRA is strongly considering an elimination of the
requirements around sub-vendors. The revised rule will likely
say that as a good business practice firms should require their
vendors to notify them of subcontracting relationships but will not
actually go so far as to require such
notification.
We support FINRA's revised position on the elimination of
sub-vendors from the rule and view this as a positive development
for the industry, as any requirements regarding sub-vendor
notification would have made industry compliance overly burdensome
(as we discussed in our April Outsourcing
Alert). Of lesser note, FINRA will be
tightening some of the proposed language of the rule to clarify
some issues. For example, it will clarify that activities with
third-parties in the ordinary course of business, such as
government securities clearing banks (i.e., Chase and Bank of New
York Mellon), foreign clearing banks (i.e., Euroclear) and
custodians, are not intended to be within the scope of this
rule
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.
To print this article, all you need is to be registered on Mondaq.com.
Click to Login as an existing user or Register so you can print this article.
A female employee traveling for her employer met a "friend" and at her motel room with him became "injured whilst engaging in sexual intercourse when a glass light fitting above the bed was pulled from its mount and fell on her."
The Departments of Labor, Treasury, and Health & Human Services have issued new guidance on the content requirements for health plan summaries of benefits and coverage ("SBCs").
Groping, insulting, and threatening female employees has just resulted in an award by a federal jury in Tampa of $20.2 million in damages in an action which alleged a hostile work environment.
