Douglas Adams Meets FINRA and the SEC . . . Really
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)...
December at the SEC: DTC Tokenization Pilot and Marketing Rule Risk Alert
As 2025 concluded, recent Securities and Exchange Commission development further highlighted significant shifts in its priorities. Beyond Staff’s most recent Examination Priorities Report, two actions stand out: its recent No Action Letter to The Depository Trust Company and its Risk Alert concerning the Marketing Rule.
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)...
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...
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 1
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...