SEC Staff Alert Reveals Expansive Application of Market Access Rule
Client Newsflash

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A National Exam Risk Alert released by the SEC’s Office of Compliance Inspections and Examinations reveals that the SEC staff is taking an expansive view of a broker-dealer’s obligations under new Rule 15c3-5, the “Market Access Rule.” The Alert points to the Market Access Rule as the basis for a broker-dealer’s obligation to monitor an array of risks from offering master-sub account arrangements. The Alert suggests that the staff of the Office of Compliance Inspections and Examinations (“OCIE”) may use the Market Access Rule’s risk management policies and procedures requirements as a basis for enforcing compliance with many other compliance obligations, particularly those involving customer surveillance and diligence.