The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement
Regulatory Supervision and Self-Regulation
Applicable regulatory and self-regulatory authorities in Japan include:
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Financial Services Agency (FSA):
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Established under the Prime Minister's Office with authority to:
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Issue business registrations to FIBOS under the FIEA
Supervise and monitor the conduct and activities of registered FIBOS
Securities Exchange Surveillance Commission (SESC)
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The "independent" arm of the FSA responsible for financial market oversight (trading regulator)
Conducts inspections of FIBOS and makes recommendations to the Commissioner of the FSA for
sanctions, etc., where appropriate
Japan Securities Dealers Association (JSDA): Self-regulatory body with oversight
responsibility for Type 1 FIBOS including administration of licensing examinations and
training (similar role to FINRA)
Type 2 Association: Recently established industry self-regulatory body with oversight
responsibility for Type 2 FIBOS
Japan Investment Advisors Association (JIAA): Industry self-regulatory body with oversight
responsibility for asset managers and investment advisors
Japan Investment Trust Association: Industry self-regulatory body with oversight
responsibility for asset managers that conduct investment trust management business
Morgan Lewis
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