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The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to its online database. FINRA also posts a monthly summary of these actions. (Reader’s Digest it is not, but that is not the point.) Setting aside whether one agrees with FINRA’s findings and sanctions, this summary offers insight into FINRA’s regulatory priorities. Below my…
Most movie fans can quote some parts of the classic courtroom showdown between Tom Cruise’s Lieutenant Kaffee and Jack Nicholson’s Colonel Jessep in the 1992 movie A Few Good Men (“You want answers?” “I WANT THE TRUTH!” “YOU CAN’T HANDLE THE TRUTH!”).
However, before this legendary showdown is an exchange between Kevin Bacon’s Captain Ross, who is prosecuting Lt. Kaffee’s…
The National Society of Compliance Professionals (NSCP) is a valuable resource for the broker-dealer and registered investment adviser compliance community. I have had the good fortune to contribute to the NSCP’s efforts in a number of ways, among which is writing articles for its Currents publication. These include:
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I do not think that it is an exaggeration to write that historically the public’s view of securities trade reporting has been a collective yawn. (In fact, that sentiment may also be true for industry participants – until, of course, it goes wrong.) This changed with a recent lawsuit filed in the U.S. District Court for the Western District of…
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then you received a message from a “@sec.gov” or “@finra.org” email address, which asked you to access a portal for additional…
In April 2024, the Securities and Exchange Commission’s Division of Examinations (“EXAMS”) posted another Risk Alert concerning the Marketing Rule (Advisers Act Rule 206(4)-1). This was EXAMS’ third Risk Alert about the rule, following those it published in June 2023 and September 2022. While I did not find anything in this trilogy that compared to Darth Vader…
Time is a valuable – and quickly fleeting – commodity. In my head, my wife and I just brought our youngest home from the hospital, but the reality is that we will be staring at an empty nest very soon. (A friend once told me that the days are long, but the years are short. How true.) Because of this,…
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then you received a message from a “@sec.gov” or “@finra.org” email address, which asked you to access a portal for additional…
