The Financial Industry Regulatory Authority (FINRA) has once more filed a rule change with the US Securities and Exchange Commission (SEC) to further delay the effective date of certain changes to its maintenance margin rule for covered agency transactions (e.g., to-be-announced transactions, specified pool transactions, transactions in collateralized mortgage obligations) until March 25, 2020. Client prevails in U.S. Supreme Court in Bullock v. BankChampaign. Dedicated to unfaltering excellence in client service, we are known for our business savvy and industry intelligence, providing creative and custom solutions for each of our clients. Complete the fields below to send your briefcase via email. The new implementation date would be March 25, 2021. Bankruptcy, Restructuring & Creditors' Rights, Employee Benefits & Executive Compensation, Real Estate Finance, Capital Markets & Commercial Mortgage Servicing, Small Business Investment Companies (SBICs), Conservation Easements & Mitigation Banking, Carbon Capture and Sequestration Tax Credit, Coalition of Collective Investment Trusts, ERISA individual prohibited transaction exemptions Guide, Patent Litigation Defense Center for NPE Claims, https://www.finra.org/sites/default/files/2019-10/sr-finra-2019-026.pdf, - FINRA once again delays implementation of amendments to FINRA rule 4210. Need Help? Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed, affiliated and member firms (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Christopher Soares* +1 202 383 0112 | Email. Amended FINRA Rule 4210 was scheduled to take effect on March 25, 2020, after previous delays due to requests by market participants that (i) FINRA reconsider the potential impact of Amended FINRA Rule 4210 on smaller and medium-sized broker-dealers; and (ii) they receive additional time to change systems and amend margining documentation to comply with Amended FINRA Rule 4210. The full notice and text are available here. FINRA IS A REGISTERED TRADEMARK OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. FINRA operates the largest securities dispute resolution forum in the United States, Report a concern about FINRA at 888-700-0028. FINRA Rule 4210 is designed to enforce application of margin requirements to covered agency transactions (bilateral forward-settling transactions in agency MBS), issued in conformity with … Ray Ramirez +1 202 383 0868 | Email Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The text of the proposed rule change is available on FINRA’s website at https://www.finra.org/sites/default/files/2019-10/sr-finra-2019-026.pdf. To report on abuse or fraud in the industry, FinPro (The Financial Professional Gateway), Securities Industry Essentials Exam (SIE), Financial Industry Networking Directory (FIND), Notice of Filing and Immediate Effectiveness. FINRA has filed with the SEC a proposed rule change to extend (to March 25, 2021) the implementation date of the amendments to FINRA Rule 4210 (margin requirements). The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. Contact FINRA at 301-590-6500. James Cain +1 202 383 0180 | Email Advises on efforts to identify a better route for a proposed new highway in Georgia. FINRA filed its latest proposed rule change to delay the implementation of Amended FINRA Rule 4210 because it will continue to consider these requests as well as potential amendments to the proposed 4210 amendments to avoid unnecessary disruption to the Covered Agency Transaction market. This delay, as well as certain changes to the amendments, are in line with BDA’s advocacy efforts and we appreciate all BDA members who helped drive those efforts. File a complaint about fraud or unfair practices. For updates and guidance related to COVID-19 / Coronavirus, click here. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global LLP. Separate multiple email addresses with semi-colons(;), Legal events and training: choose a location, Blockchain Use-Cases for Financial Institutions, Intersection of Anti-Money Laundering and RegTech. Authors: Application submitted to the District of Columbia Bar. FINRA filed the proposed rule change for immediate effectiveness and requested that the SEC waive the requirement that a proposed rule change not become operative for 30 days after its filing. Eversheds Sutherland is an international top 10 law practice helping a global client base ranging from small and mid-sized businesses to the largest multinationals solve their biggest challenges and reach their business goals. Amendments to FINRA Rule 4210 (mortgage margin requirements), FINRA & MSRB’s Retail Confirmation Mark-up Disclosure Rules, SEC and MA Temporary Conditional Exemption. Amended FINRA Rule 4210 will require the margining of: (1) specified pool transactions; (2) transactions in collateralized mortgage obligations, issued in conformity with a program of an agency or a government-sponsored enterprise, with forward settlement dates (collectively, Covered Agency Transactions); and (3) to-be-announced transactions, including adjustable-rate mortgage transactions. 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If you have any questions about this Legal Alert, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work. Margin Requirements. Comments on the proposed rule change should be submitted on or before the date which is 21 days from its publication in the Federal Register, which has not yet occurred. Financial Industry Regulatory Authority, Inc. (“FINRA”) is filing with the Securities and Exchange Commission (“SEC” or “Commission”) a proposed rule change to extend, to March 25, 2021, the implementation date of the amendments to FINRA Rule 4210 (Margin Requirements) pursuant to SR-FINRA-2015-036, other than the amendments pursuant to SR-FINRA-2015-036 that were implemented on December 15, 2016. Lizet Steele +1 202 383 0942 | Email As a result, addressing counterparty exposure to credit risk remains a priority for the regulators in their quest to secure global financial markets. FINRA has filed with the SEC a proposed rule change to extend (to March 25, 2021) the implementation date of the amendments to FINRA Rule 4210 (margin requirements). If you have any questions about this legal alert, please feel free to contact any of the attorneys listed under 'Related People/Contributors' or the Eversheds Sutherland attorney with whom you regularly work. As such, FINRA is proposing to extend the March 25, 2020 implementation date by an additional year, to March 25, 2021 while FINRA considers potential amendments.” The text of the rule change is available here. FINRA has recently submitted a filing with the Securities and Exchange Commission (“SEC”) to propose another delay to the implementation of TBA margin requirements under Rule 4210. Industry and business experience makes the difference for our clients. *Not admitted to practice. U.S. Immigration court grants asylum to an Ethiopian refugee in Sutherland pro bono matter. The Financial Industry Regulatory Authority, Inc. (FINRA) filed a proposed rule change with the Securities and Exchange Commission (SEC) on October 25, 2019, to once more delay the implementation of amendments to FINRA Rule 4210 (Amended FINRA Rule 4210) until March 25, 2021. Data Analytics in Compliance, Examinations and Enforcement. FINRA believes that this is appropriate in the interest of avoiding unnecessary disruption to the Covered Agency Transaction market. 4210. The Financial Industry Regulatory Authority, Inc. (FINRA) filed a proposed rule change with the Securities and Exchange Commission (SEC) on October 25, 2019, to once more delay the implementation of amendments to FINRA Rule 4210 (Amended FINRA Rule 4210) until March 25, 2021. ... FINRA, upon written application, may reduce the deduction to net capital under Rule 4120 to 25 percent of such aggregate credit extended that exceeds 10 percent but is less than 15 percent of the member's excess net capital. Financial Industry Regulatory Authority, Inc. (“FINRA”) is filing with the Securities and Exchange Commission (“SEC” or “Commission”) a proposed rule change to extend, to March 25, 2021, the implementation date of the amendments to FINRA Rule 4210 (Margin Requirements) pursuant to SR-FINRA-2015-036, other than the amendments pursuant to SR-FINRA-2015-036 that were implemented … This delay, as well as certain changes to the amendments, are in line with BDA’s advocacy efforts and we appreciate all BDA members who helped drive those efforts. While TBA transaction benefits are recognized widely, they are exposed to counterparty default risk due to forward settlement dates that occur in the future (up to several months).
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