With Apologies to George Carlin

George Carlin was one of the best.  Not only did he help Alex Winter and Keanu Reeves save the world, but also put together the authority on what makes baseball different from football. (“Baseball begins in the spring, the season of new life. Football begins in the fall, when everything’s dying.”)  He also memorialized his –...
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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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