Private Placement Brokers and Finders, Oh My

In October of 2016, the SEC approved FINRA rules allowing for the registration of limited purpose broker-dealers, called capital acquisition brokers or CABs (see my blog post on November 1, 2016). This set of rules came about from a No-Action letter issued the year before that granted a no-action position for a very limited exemption […]

Re-Engaging

When I started my blog  I had a vision of a dialogue among professionals engaged in the securities industry. But at that time I was more of a lawyer than an entrepreneur. Lawyers believe that everyone wants to understand the smallest detail about a law. What I have found is that clients and prospective clients […]

SEC Examination Priorities for 2018

Today February 7, 2018, the SEC released its Examination Priorities for 2018. Their focus this year is the retail investor. Prior areas of focus have been subcategorized under the larger retail market. Those include: electronic investment advice, fixed income execution, mutual funds and ETFs, never examined registered investment advisors, wrap accounts and municipal advisors and […]

HAPPY NEW YEAR

Happy New Year. I know it is a new year because FINRA has issued its Regulatory and Examination Priorities Letter. As with every yearly letter, it mostly covers the topics from the prior year. This year Operational and Financial Risks are clearly going to be a focus of examinations. Not surprising in the Sales Practice Section […]

New Look and Feel

As I open my new law office I decided it was time to relaunch my Blog/Website. So as of today I have a new look on my Blog. Come back as I write not only about broker-dealers, investment advisors and other financial institutions, but also about the practice of law for those entities. Also you […]