SEC Archives

Yet Another Assortment of . . .

Posted on May 23, 2023

Brain Droppings! George Carlin’s Brain Droppings is an inspiration for my micro-blog on LinkedIn. Below are some of my most recent posts. The Financial Professionals Coalition, Ltd. For those of you in the registered investment adviser or broker-dealer space,...

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...

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 –...

Not Quite the “Wild West”

Posted on June 13, 2022

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...

EXAMS’ Risk Alert on Advisers Act Section 204A and the Code of Ethics Rule

Posted on May 5, 2022

The SEC’s Division of Examinations (“EXAMS”) posted its observations concerning registered investment advisers’ compliance with Section 204A of the Investment Advisers Act of 1940 and Rule 204A-1 (also known as the “Code of Ethics Rule”) in...

Social Media Hygiene and Recordkeeping

Posted on April 6, 2022

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...