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SEC Grants Temporary Exemption From Certain Requirements of Rule 606 of Regulation NMS

On March 25, the Securities and Exchange Commission issued an Order granting the application by the Financial Information Forum (FIF) and Securities Traders Association (STA) for a temporary exemption from certain requirements of Rule 606 of Regulation NMS under the Securities Exchange Act of 1934, which requires broker-dealers to disclose certain information regarding the handling of their customers’ orders, as a result of COVID-19. The SEC granted the request of FIF and STA that the SEC: 1) delay the date by which broker-dealers must provide the public report of first quarter 2020 data required by Rule 606(a) to May 29, 2020; and 2) extend the date that broker-dealers that outsource routing must begin to collect the monthly customer-specific data for not held NMS stock orders required by Rule 606(b)(3) to June 1, 2020, and extend to July 29, 2020, the date by which broker-dealers must provide the customer-specific report of June 2020 data for customer requests that are made on or before July 17, 2020.

The SEC Order is available here.

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About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York
Partner

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

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212-940-8599
Michael T. Foley, Katten, Lawyer, Finance, FINRA, Chicago
Special Counsel

Michael Foley represents broker-dealers, investment advisers and other financial services industry participants with respect to a broad spectrum of legal and regulatory matters arising under the federal securities laws.

Michael has nearly 20 years of experience in private practice and in-house at both a large, full-service broker-dealer and at an online discount broker-dealer, advising broker-dealers and other financial institutions regarding compliance with the federal securities and commodities laws, and with the regulations of the US Securities and Exchange Commission, the US Commodity Futures Trading Commission and financial industry self-regulatory organizations. 

312-902-5452
Jack West Financial Attorney Katten
Associate

Jack West is an associate in the Financial Markets and Funds practice.

312-902-5463