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...
Another Batch of Brain Droppings Continue reading…

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!"...
My January Brain Droppings Continue reading…

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...
Yet Even More Brain Droppings – Broker-Dealer Edition Continue reading…
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...
Even More Brain Droppings – Consolidated Audit Trail (CAT) Edition Continue reading…
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...
More Brain Droppings – Digital Assets Edition Continue reading…

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 –...
With Apologies to George Carlin Continue reading…

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...
Expungement? Not So Fast, My Friend Continue reading…

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...
Is The Past Prologue? FINRA Permits Remote Inspections . . . For Now Continue reading…

Not Quite the “Wild West”
Last week Congress received a bill that would grant the Commodity Futures Trading Commission, not the Securities and Exchange Commission, jurisdiction over the growing digital assets market. The goal is to, as CNBC put it, tame the “’Wild West’ crypto...
Not Quite the “Wild West” Continue reading…

FINRA’s Expectations (Reg Notice 22-11)
FINRA issued Regulatory Notice 22-11 in April to remind broker-dealers of their obligations in the sale of alternative mutual funds to their clients. FINRA explained that it published this guidance because of a number of recent enforcement actions it took against firms selling this product. However, upon closer inspection, 22-11 is simply FINRA’s...
FINRA’s Expectations (Reg Notice 22-11) Continue reading…