NSCP Volunteer

For Compliance

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. ...

For Compliance Continue reading…

A Trilogy in Five Parts

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)...

A Trilogy in Five Parts Continue reading…

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...

Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 5 Continue reading…

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 4 Continue reading…

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...

Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 3 Continue reading…

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...

Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 2 Continue reading…

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...

Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 1 Continue reading…
|

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...
So, You Want To Be a CCO? Continue reading…

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...
Regulatory Notice 22-10 Continue reading…