February 20, 2015
Mr. Gregory J. Nowak
Pepper Hamilton LLP
3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
Re: FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Dear Mr. Nowak:
This is in response to your letter dated December 3, 2014, in which you request interpretive guidance on behalf of PCV Lux, SCA ("PCV
Bill Wollman is Executive Vice President, Office of Financial and Operational Risk Policy. In this role, he is responsible for FINRA’s policy and rulemaking efforts relating to broker-dealer financial responsibility rules, operational issues, customer protection requirements and margin standards. Mr. Wollman is one of the senior leaders who is responsible for leading FINRA’s response to firms
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Senior ManagementCorporate FinanceInstitutionalSystemsTrading
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EXECUTIVE SUMMARY
In a report titled "Clearance and Settlement Systems in the World's Securities Markets," a private-sector group published nine recommendations proposing standards for clearance and settlement of
Conflicts of interest can arise in any relationship where a duty of care or trust exists between two or more parties, and, as a result, are widespread across the financial services industry. While the existence of a conflict does not, per se, imply that harm to one party’s interests will occur, the history of finance is replete with examples of situations where financial institutions did not
SummaryFINRA, as a self-regulatory organization, is informed by and benefits from the expertise of industry and other stakeholders. As such, FINRA has multiple committees that facilitate effective engagement with member firms and representatives of the public regarding regulatory and policy initiatives related to FINRA’s mission of promoting market integrity and investor protection. The purpose
Please allow retail investors the ability to trade LETFs. The prospectus makes it clear the risk imposed onto the investor.
FINRA advises each member firm to review the Report and consider incorporating relevant elements into its compliance program in a manner tailored to its activities. The Report is intended to be just one of the tools a member firm can use to help inform the development and operation of its compliance program; the Report does not represent a complete inventory of regulatory obligations, compliance considerations, findings, effective practices or topics that FINRA will examine.
I assume all risk as I invest.
i am fully reconized risk.