ARTICLE
5 October 2021

Effective Date Set For FINRA Rule Imposing Additional Obligations On Firms With A History Of Misconduct

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.
New FINRA Rule 4111, which imposes additional requirements on broker-dealers deemed to pose a significant risk to investors, will go into effect on January 1, 2022.
United States Finance and Banking
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New FINRA Rule 4111 ("Restricted Firm Obligations"), which imposes additional requirements on broker-dealers deemed to pose a significant risk to investors, will go into effect on January 1, 2022.

As previously covered, the new rule concerns firms with "significantly higher levels of risk-related disclosures (including sales-practice related disclosure events) than other similarly sized peers based on numeric, threshold-based criteria." The rule subjects restricted firms to additional limitations on their conduct or operations and requires them to post assets in a segregated account.

Primary Sources

  1. FINRA Regulatory Notice 21-34: FINRA Adopts Rules to Address Firms With a Significant History of Misconduct

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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