Yet Another Assortment of . . .

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, consider checking out the Financial Professionals Coalition, Ltd. The Coalition is a diverse resource for over 1.2 million registered representatives, associated persons, traders, bankers, back-office staff, and owners of broker-dealers and registered investment advisors. It provides courtesy consultations with industry experts. Membership is free.

New Reg BI Guidance Focuses on Care Obligations At Heart of Recent Enforcement

Years ago an experienced lawyer asked me and other newly-minted attorneys where was the best place to start researching an answer to a legal question. He liked my answer of “First, statutes. Then, rules.” Of course, with the benefit of (always 20/20) hindsight, I should have added “And finally, regulatory guidance.”

Indeed, sometimes the regulators proverbial two cents is the best place to find answers. Of course, the flip side to this coin (yes, I like my idioms) is when one comes across a regulator who tries to apply a regulatory notice or similar guidance with the force of a statute or rule. That aside, more guidance is typically better – particularly when, as is the case here, it concerns a new rule set.

CAIS Compliance Deadlines

Lost amid the din of the SEC’s slate of proposed rules is the fact that broker-dealers still have to contend with the last phases of the CAT build out. FINRA CAT announced today that it will announce the new deadlines for Interim Reporting Obligation 4 and Full CAIS Compliance Go-Live no later than August 15, 2023, and importantly, these deadlines will not be before the fourth quarter of 2023.

Alzheimer’s Association’s Legal Industry Leadership Council

The actions you take today not only honor those who came before you and celebrate those who are with you, but these help create the path for those who will follow you. If you are a lawyer and your actions today include supporting a charitable organization, then please consider the Alzheimer’s Association® Legal Industry Leadership Council. Chances are that you know someone who this disease or other forms of dementia has impacted in some way.

NASAA Members Admit Guam as a Member and Approve Two Regulatory Proposals

In the spate of recent rule proposals and amendments in the securities industry (hello, House Financial Services Committee), here comes a welcome change: a regulatory initiative that almost everyone can support. NASAA has approved a model rule that permits representatives of registered investment advisers to leave the industry for up to five years without having to requalify by exam so long as they complete their continuing education requirements. This aligns the states (as they adopt the rule, of course) with the FINRA counterpart for broker-dealers – the MQP.

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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 help 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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