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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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...
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EXAMS’ Risk Alert on Advisers Act Section 204A and the Code of Ethics Rule
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...
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Social Media Hygiene and Recordkeeping
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...
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Defend Yourself
It rarely ends well for an RIA who fails to appear before the Securities and Exchange Commission to defend his or her position. Witness the latest industry bar.
Are you facing a SEC action? Please contact me to discuss.
Read more:
Expungement of Complaints from the CRD
The SEC's 2022 Examination Priorities
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