The Financial Industry Regulatory Authority, Inc. (“FINRA”) recently filed an immediately effective proposal with the Securities and Exchange Commission (“SEC”) to adopt new rules aimed at certain abusive forms of electronic trading. The proposed rules prohibit two specific types of disruptive quoting and trading activity, and permit FINRA to bring expedited cease and desist proceedings against violations, even if there is no showing of improper intent. The proposal was published by the SEC on November 21, and will become operative on December 15 (see SR-FINRA-2016-043, available here).
David Freeman is head of the firm’s Financial Services practice group. He represents financial institutions, investment managers, and broker-dealers on banking and securities regulatory issues, legislation, mergers and acquisitions, private investment funds, and new product development and documentation. As part of his practice, Mr. Freeman advises domestic and foreign banks, investment management firms, and broker-dealers on compliance with state and federal banking and securities laws, federal commodities laws, and SRO rules.