Law and Order – January 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 priorities. Below, I offer...
Douglas Adams Meets FINRA and the SEC . . . Really
From "Don't panic" to "So once you do know what the question actually is, you'll know what the answer means" to "I don’t know what I’m looking for . . ." to "Life’s bad enough as it is without wanting to invent any more of it" to (finally)...
Law and Order – December 2025
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 priorities. Below is...
6 Tips for Writing Supervisory Procedures – The ABCs
SEC Rule 206(4)-7(a) requires registered investment advisers to implement written policies and procedures reasonably designed to prevent violation of the Investment Advisers Act of 1940 and related rules. Similarly, under FINRA Rule...
December at the SEC: DTC Tokenization Pilot and Marketing Rule Risk Alert
As 2025 concluded, recent Securities and Exchange Commission development further highlighted significant shifts in its priorities. Beyond Staff’s most recent Examination Priorities Report, two actions stand out: its recent No Action Letter to The Depository Trust Company and its Risk Alert concerning the Marketing Rule.
Law and Order – November 2025
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it has taken to its online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those in the industry – if only to gain insight into FINRA’s regulatory priorities. Below,...
E-Mail Retention
The broker-dealer and RIA sectors have long been aware that the criteria for maintaining and overseeing digital communications are stringent. And unforgiving. has long been aware that the criteria for maintaining and overseeing digital communications are stringent. And unforgiving. See https://www.thinkadvisor.com/2025/10/09/finra-hits-ally-invest-securities-with-850k-fine-over-emails/ for another example. More cases will arise as long as humans...
Law and Order – October 2025
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it has taken to its online database. It also posts a monthly summary of these actions, which is a worthwhile read for those in the industry – if only to gain insight into FINRA’s regulatory...
A Recipe for Failure
The firm's surveillance system generated more than 10,000 alerts over a two-month period. It also flagged approximately 15.2 million items over a two-year period with over 5.2 million still unreviewed at the time of the disciplinary action. If that were not enough - and stop me if you have heard this before...
Law and Order – August 2025
The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to its online database. It also posts a monthly summary of these actions, which is a worthwhile read for those in the industry - if only to gain insight into FINRA’s...