The following post is based on a memo originally published by Davis Polk & Wardwell on January 8, 2014. The original publication is available here.
Financial Industry Regulatory Authority (“FINRA”) rules require broker-dealer members to establish and maintain a system and written procedures to supervise the activities of their personnel, which are reasonably designed to achieve compliance with the federal securities laws and FINRA rules. As part of FINRA’s rulebook consolidation process, on December 23, 2013, the SEC approved FINRA’s proposal to consolidate several existing NASD and NYSE rules and interpretations relating to supervision into new FINRA rules.
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