Federal Preemption
I recently had the opportunity to assist the Alternative & Direct Investment Securities Association (ADISA) with a comment letter to the Securities and Exchange Commission concerning the SEC’s proposed reforms for federal preemption of registered offerings.
Exchange-listed securities generally benefit from federal preemption of state registration and...
Law and Order – July 2026: Check the Box and Miss the Point
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those in the industry—if only for insight into FINRA’s current priorities. Below, I offer my...
Law and Order – June 2026: Ask One More Question
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those in the industry—if only for insight into FINRA’s current priorities. Below, I offer my...
Before You Paste That Into AI, Read This
Artificial intelligence is moving into the workplace at a remarkable pace. Depending on who you ask or the day, it is either going to revolutionize business or end civilization. The truth, as usual, is probably somewhere in the middle. What is not up for debate is that AI has become an extraordinarily...
Law and Order – May 2026: The Comfort Crisis
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those...
Finding Balance: Curly Was Right
I have written a fair amount over the years about SEC examinations, FINRA enforcement actions, compliance programs, and the various ways regulators can complicate an otherwise pleasant afternoon.
This is not one of those posts.
Instead, I want to revisit one of the more important lessons...
Law and Order – April 2026
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for...
The CAT is Back on the Vet’s Exam Table: What the SEC’s New Concept Release Means
I’ve been around the Consolidated Audit Trail (CAT) long enough to remember when it was still mostly a noun clause and a gleam in a regulator’s eye. Now it is a fully grown animal—expensive, complicated, and the subject of renewed scrutiny. On April 16, 2026, the SEC issued...
Law and Order – March 2026
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those in the industry—if only for insight into FINRA’s current priorities. Below, I offer a...
Finally Something to Welcome on April 15
Broker-dealers familiar with FINRA’s “filing cabinet” system know it has often been cumbersome. In Regulatory Notice 26-09, FINRA announced enhancements to the Form NMA for applicants seeking FINRA membership before the Membership Application Program (MAP)...