The ABCs of WSPs
Most movie fans can quote some parts of the classic courtroom showdown between Tom Cruise’s Lieutenant Kaffee and Jack Nicholson’s Colonel Jessep in the 1992 movie A Few Good Men (“You want answers?” “I WANT THE TRUTH!” “YOU CAN’T HANDLE THE TRUTH!”).
However, before this...
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. ...
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)...
Not the Same CAT
I do not think that it is an exaggeration to write that historically the public’s view of securities trade reporting has been a collective yawn. (In fact, that sentiment may also be true for industry participants – until, of course, it goes wrong.) This changed with a recent lawsuit filed in...
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...
It Is Still Art
In April 2024, the Securities and Exchange Commission’s Division of Examinations (“EXAMS”) posted another Risk Alert concerning the Marketing Rule (Advisers Act Rule 206(4)-1). This was EXAMS’ third Risk Alert about the rule, following those it published in June 2023...
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 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 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...
Well, At Least It Is Not The T-1000
Memorial Day weekend typically brings us open swimming pools, trips to the beach and smells of charcoal (lump only, of course) as far as the nose takes us.
And this year, the shortening of the settlement cycle for most broker-dealer transactions from 2 days to 1, or T+1, on...