FINRA recently adopted important changes to FINRA Rule 3240 to tighten restrictions on borrowing and lending arrangements between registered persons and their customers. The changes go into effect on April 28, 2025, and broker-dealers should be taking steps now to prepare. This client alert breaks down what the changes mean and outlines key implementation considerations.

On September 4, 2024, the California Attorney General’s office reached a $3.9 million settlement with a cryptocurrency trading platform. This marks the first public enforcement action by the California Department of Justice against a cryptocurrency company, as well as the first application of the state's commodity laws to cryptocurrency. While the CA DOJ’s focus on consumer protection is commendable, the Settlement exhibits features of “regulation by enforcement.” Its lack of specific legal guidance leaves cryptocurrency companies uncertain about how California laws apply to their operations.