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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 been a lot of them lately.  Below are some of my most recent posts.

FINRA’s Expungement Rules Just Got Tougher

Not surprisingly, the SEC approved FINRA’s amendments to its arbitration rules governing expungement proceedings. I am very interested to see how the provisions requiring notice to state regulators and an opportunity for the regulator(s) to participate in the proceedings will play out. Clearly, these will not be your routine third-party intervenors.

Walk to End Alzheimer’s

Yes, there are many fantastic charity events to support. Please consider putting this on your short list as chances are you know someone who benefits from the Alzheimer’s Association® efforts.

SEC staff having trouble keeping up with rule-making pace — report

Although this article came out 6 months ago, it seemed reposting it now was appropriate. Of course, broker-dealer and registered investment advisor compliance officers — not the SEC staff — will be responsible for building and implementing any systems needed to ensure compliance with the new rules.

FINRA Shares Effective Practices to Address Risks of Fraudulent Transfers of Accounts Through ACATS

FINRA posting a regulatory notice about issues associated with the Automated Customer Account Transfer Service (ACATS) is noteworthy. Posting a second (RN 23-06) within 6 months is remarkable. Broker-dealers are well served to take note of the best practices. As I observed following FINRA’s issuance of RN 22-21, once the assets are gone, they are gone. Moreover, an account transfer gone away could also lead to AML obligations.

Exercise Can Be the Best Antidepressant

I typically post news concerning the registered investment adviser or broker-dealer communities, usually about the SEC or FINRA, and often with some sort of analysis. Today, I will simply leave this article here with “Agreed”.

SEC Proposes to Modernize the Submission of Certain Forms, Filings, and Materials Under the Securities Exchange Act of 1934

This would have been helpful during the pandemic, but I am not about to look a gift horse in the mouth.

SEC Office of Municipal Securities Issues FAQs for Registration of Municipal Advisors

Dodd Frank has been in the news lately . . . for all of the wrong reasons. (Hello, SVB, Signature, . . .) But this law was not just for banks, another component of this law provided for the registration of municipal advisors. The SEC has issued updated guidance.

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Thank you for reading this article.  Please know that I wrote it for informational purposes only (some may consider it ADVERTISING MATERIAL) and did not intend for it to be legal advice or to form an attorney-client relationship with you – especially in jurisdictions where I am not licensed to practice law.  I encourage you to seek your own counsel to help you with your specific situation.  To that end, I invite you to contact me if you would like to discuss my services.

I enable broker-dealers, registered investment advisers and their associates to spend more time growing their business by helping them address a wide range of legal and compliance responsibilities.

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