FINRA’s March Disciplinary Actions
Industry participants know that FINRA’s monthly posting of its "Disciplinary and Other FINRA Actions" offers insight into its enforcement priorities. One can also say it offers various teaching moments. The March edition is no exception.
Of interest to me was a Letter of Acceptance, Waiver and Consent (AWC) that FINRA accepted from a broker-dealer to...
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Social Media Hygiene and Recordkeeping
Reporter Dalvin Brown advised that “deleting old social-media posts is good hygiene, no matter who you are.” See The Wall Street Journal, How to Delete Your Old Posts on Instagram, Facebook and Twitter (posted February 20, 2022). Agreed. Posting to social media can lead to unintended, and sometimes severe, consequences. However, industry practitioners are reminded...
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So, You Want To Be a CCO?
In Regulatory Notice 22-10, FINRA offers the broker-dealer community guidance on when it will consider charging a Chief Compliance Officer under Rule 3110. Equally as important, FINRA articulates the factors that it may consider when deciding not to level such a charge. The clarity is helpful. And worth any CCO’s careful examination.
FINRA...
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The MQP
The Ides of March brought a meaningful change for the registered representative community – the launch of the Maintaining Qualifications Program, or MQP. As FINRA announced in Regulatory Notice 21-41, under the changes to Rule 1240(c), those who terminate any representative or principal registration category on or after March...
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Defend Yourself
It rarely ends well for an RIA who fails to appear before the Securities and Exchange Commission to defend his or her position. Witness the latest industry bar.
Are you facing a SEC action? Please contact me to discuss.
Read more:
Expungement of Complaints from the CRD
The SEC's 2022 Examination Priorities
...
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Did FINRA Just Preview its 2023 Report?
In Regulatory Notice 22-08, FINRA reminds its membership of their obligations when selling certain products and invites comment on whether the current regulatory framework is sufficient given today's practices. Industry members should also note that at page 9 FINRA offers a few observations stemming from its current targeted exam of options accounts and...
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Regulatory Notice 22-10
FINRA just posted guidance on potential Chief Compliance Officer liability stemming from Rule 3110 violations in Regulatory Notice 22-10.
Read more:
The MQP
Defend Yourself
EXAMS’ Risk Alert on Advisers Act Section 204A and the Code of Ethics Rule
FINRA’s April 2022 Disciplinary and Other Actions
Expungement of Complaints...
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The 2022 Report on FINRA’s Examination and Risk Monitoring Program
The 2022 Report is Worthy Reading for Every Compliance Officer
If you are in the broker-dealer industry, reading the 2022 Report on FINRA’s Examination and Risk Monitoring Program is worth your time and attention – especially if you are a supervisory principal or other compliance officer. FINRA not only highlights key issues in...
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