Keegan Farley

Dechert are most popular: within Real Estate and Construction and Strategy topic(s) with readers working within the Banking & Credit industries On February 12, 2026, the SEC approved FINRA's proposed rule change to amend FINRA Rule 3220 (Influencing or Rewarding Employees of Others) (the "Gifts Rule").1 Among other things, the amendment: increases the gift limit from $100 to $300 per gift recipient per year; makes conforming changes to the limits in FINRA's "Non-Cash Compensation Rules;"2 and...

Prior to recent rule amendments, non-traded and private BDCs were, as a practical matter, largely unable to participate in IPOs. The recently adopted amendments create a categorical exemption for all BDCs to purchase new shares so long as they were not "formed or maintained for the specific purpose of permitting restricted persons to invest in new issues." FINRA adopted amendments to exempt business development companies ("BDCs") from FINRA Rule 5130 (Restrictions on the Purchase and Sale of...

U.S. financial services providers who transacted in financial services with non-U.S. persons in the 2024 fiscal year may be required to file the Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons (BE-180) by July 31, 2025 (unless they obtain an extension).