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

Posted on April 10, 2024

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 1

Posted on April 3, 2024

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...

Home Sweet Home

Posted on March 30, 2024

This June, the Financial Industry Regulatory Authority (FINRA) will permit a broker-dealer to designate a home office as a “Residential Supervisory Locations” (RSL) within its supervisory structures. (While this is certainly welcome news, as Vince Neil will tell you, just when things went right, it doesn't mean they were always wrong.) The...

More Thoughts, Ideas and uh, Brain Droppings

Posted on April 28, 2023

As noted time and time again, George Carlin’s Brain Droppings is as an inspiration for my micro-blog on LinkedIn. There I frequently comment on events affecting the broker-dealer and registered investment adviser communities. And there have...

Another Batch of Brain Droppings

Posted on March 24, 2023

George Carlin’s philosophy tome, Brain Droppings, is as an inspiration for my micro-blog on LinkedIn. Below are some of my most recent posts. Firms Face Choppy Water Navigating SEC Compliance Dates “Regulation does not exist in a vacuum.” I appreciate Investment Adviser Association President Barr saying very publicly (and to...

My January Brain Droppings

Posted on March 20, 2023

George Carlin was one of our best modern-day philosophers, and his book Brain Droppings served as an inspiration for my micro-blog on LinkedIn. Below are some of my posts for January. FINRA Amends FINRA Rule 2231 I have not heard anyone exclaim "Oh good, my securities account statement is here!"...

Yet Even More Brain Droppings – Broker-Dealer Edition

Posted on February 19, 2023

Comedians are some of our best modern-day philosophers, and as I noted earlier, George Carlin was one of the best. He captured his musings, beliefs, etc. in many books. One of which is Brain Droppings, which...

Even More Brain Droppings – Consolidated Audit Trail (CAT) Edition

Posted on January 30, 2023

I am convinced that if Plato was alive, then he would be spending his time at the D.C. Improv whenever he came to town. Yesterday’s philosophers are today’s comedians, and as I noted earlier, George Carlin was one of the best. Carlin captured his -uh- philosophy in many tomes, including Brain Droppings, which I shamelessly...

More Brain Droppings – Digital Assets Edition

Posted on January 24, 2023

Comedians are some of our best modern-day philosophers, and as I noted earlier, George Carlin was one of the best of the best. He captured his musings, beliefs, etc. in many books. One of which is Brain Droppings, which I shamelessly stole as an inspiration for my micro-blog on LinkedIn. FTX’s implosion has thrust cryptocurrencies and...

With Apologies to George Carlin

Posted on October 22, 2022

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 –...