
Home Sweet Home
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
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...
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Another Batch of Brain Droppings
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...
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My January Brain Droppings
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!"...
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Yet Even More Brain Droppings – Broker-Dealer Edition
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...
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Even More Brain Droppings – Consolidated Audit Trail (CAT) Edition
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...
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More Brain Droppings – Digital Assets Edition
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...
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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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Expungement? Not So Fast, My Friend
This Is The Business We’ve Chosen
Associated persons (an “AP”) know all too well that the regulators post a considerable amount of information about their history online – particularly, allegations of misconduct. This information can lead to, among...
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Is The Past Prologue? FINRA Permits Remote Inspections . . . For Now
On July 1, FINRA amended Rule 3110.17 to allow broker-dealers to remotely inspect offices of supervisory jurisdiction (OSJs), branch offices and non-branch locations through the end of 2022. The substantive requirements remain unchanged. A broker-dealer must: (1) have procedures for...
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