The Securities Industry/Regulatory Council on Continuing Education (Council) recently released its Firm Element Needs Analysis Quarterly Highlights (formerly known as Firm Element Advisory) to assist industry participants with the identification of potential topics to include in Firm Element training plans. The Council has identified the topics from a review of the industry, regulatory and self-regulatory organization (SRO) announcements, and publications of significant events.
The Council suggests that firms use the FE Training Ideas Firm Element Needs Analysis Quarterly Highlights as an aid in evaluating and prioritizing their Firm Element needs and developing written training plans. However, firms are reminded to not rely on the report as a comprehensive list of all areas they should consider. This article summarizes the Council’s complete guide and strictly focuses on the “New” material that was listed in the recent Firm Element Advisory (FEA).
CYBERSECURITY AND TECHNOLOGY GOVERNANCE
(New) Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure
The Commission is adopting new rules to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incidents by public companies that are subject to the reporting requirements of the Securities Exchange Act of 1934. Specifically, we are adopting amendments to require current disclosure about material cybersecurity incidents. We are also adopting rules requiring periodic disclosures about a registrant’s processes to assess, identify, and manage material cybersecurity risks, management’s role in assessing and managing material cybersecurity risks, and the board of directors’ oversight of cybersecurity risks. Lastly, the final rules require the cybersecurity disclosures to be presented in Inline eXtensible Business Reporting Language (“Inline XBRL”). The amendments are effective September 5, 2023.
(New) MSRB Adopts Amendments to Rules G-12 and G-15, Shortening Regular-Way Settlement Transaction to T+1
The Municipal Securities Rulemaking Board (MSRB) received approval from the SEC on May 25, 2023, for amendments to MSRB Rules G-12, on uniform practice, and G-15, on confirmation, clearance, settlement and other uniform practice requirements with respect to transactions with customers. The amendments approved by the Commission amend MSRB Rules G-12 and G-15 to define regular-way
settlement for municipal securities transactions as occurring one business day after the trade date (“T+1”) and make a technical amendment to Rule G-12 to update an outdated cross-reference. The amendments align with regular-way settlement on T+1 for equities and corporate bonds under Exchange Act Rule 15c6- 1 (“Amended SEC Rule 15c6-1”) to further shorten the settlement process, requiring the settlement of most equity and corporate bond transactions on T+1. The compliance date for the amendments is May 28, 2024, which is aligned with the implementation date for Amended SEC Rule 15c6-1.
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