Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 5
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...
It Is Still Art
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...
Bigger Than Me
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...
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 4
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...
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 3
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...
A Carbon Copy Unlike Any Other
ATTENTION broker-dealers that post order routing reports pursuant to SEC Rule 606(a): You have a new reporting obligation. Starting with the Rule 606(a) report for the second quarter this year -- which, of course, is due on or before July 31 -- you must also file your report with FINRA...
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 2
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...
Well, At Least It Is Not The T-1000
Memorial Day weekend typically brings us open swimming pools, trips to the beach and smells of charcoal (lump only, of course) as far as the nose takes us.
And this year, the shortening of the settlement cycle for most broker-dealer transactions from 2 days to 1, or T+1, on...
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 1
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...
Home Sweet Home
This June, the Financial Industry Regulatory Authority (FINRA) will permit a broker-dealer to designate a home office as a “Residential Supervisory Locations” (RSL) within its supervisory structures. (While this is certainly welcome news, as Vince Neil will tell you, just when things went right, it doesn't mean they were always wrong.) The...