Our client alert discuss recent SEC rulemakings covering proposed new “Regulation Best Execution” (new Exchange Act Rules 1100, 1101, and 1102 establishing a best execution standard and requiring robust policies and procedures for firms engaging in certain conflicted transactions with retail customers); a proposed new “Order Competition Rule” (new Exchange Act Rule 616, including requiring certain retail equity orders to be exposed in auctions before being internalized); amendments to Exchange Act Rule 605 (enhancing broker disclosure of order execution information); amendments to Exchange Act Rules 610 and 612 (amending minimum pricing increments and exchange access fee caps and enhancing the transparency of better-priced orders); and amendments to Exchange Act Rule 10b5-1 (including requiring enhanced disclosures related to insider trading plans).
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