Exemptive relief is denied based on: Firm D was subject to a ban that was discernible via a review of publicly available Forms G-37 which disclosed that a PAC controlled by Firm D or a Firm D MFP made political contributions to the Issuer Officials; Firm D had a long history of making contributions to the Issuer Officials; the ban attached to Firm A upon completion of the acquisition of Firm D; neither Firm A nor Firm D attempted to obtain refunds of the contributions; Firm A’s proposed supervisory systems are not adequate to address regulatory concerns presented.
SEC Approves Amendments to the FINRA Rule 9550 Series Governing Expedited Proceedings
New System for Processing Regulation T and SEA Rule 15c3-3 Extension of Time Requests
INFORMATIONAL
Prohibition Against Guarantees and Sharing in Customer Accounts
Effective Date: May 12, 2003
SUGGESTED ROUTING
KEY TOPICS
Executive Representatives
Legal & Compliance
Senior Management
Registered Representatives
Principals
FINRA Small Firm Advisory Board Election
SEC Approves Amendments to FINRA Trade Reporting Rules on OTC Equity Transactions Executed Outside Normal Market Hours
SEC Approves Amendments to FINRA Dispute Resolution, Inc. By-Laws to Classify Mediators as Public Members if They Are Not Otherwise Disqualified From Being Classified as Public Members
SEC Approves Amendments Relating to Recordkeeping and the Unsolicited Customer Order Exception of SEA Rule 15c2-11
FINRA Adopts Amendments Relating to Reporting Transfers of Proprietary Positions in Debt and Equity Securities in Connection With Certain Corporate Control Transactions
Exemptive relief is granted based on the following factors: (1.) prior to Name's contribution, Firm X maintained a thorough and comprehensive set of procedures reasonably designed to ensure compliance with the Rule; (2.) the Firm had no knowledge of Name's contribution; (3.) once Firm X learned of Name's contribution, it took all available steps to return of the contribution; (4.) Firm X took appropriate remedial or preventive measures.
