Category: Books and Records

Written by Sharon M. Davison

Don’t Just Wait!

So you got your Form ADV filed with the SEC and you are waiting for March 31. Don’t just wait. As I wrote back in December registration is just the beginning of the journey. Now is the time to find the kinks in your compliance and supervisory programs. Over the next month you should systematically […]

Written by Sharon M. Davison

FINRA Fails to Furnish Complete and Accurate Records

This headline flashed across my computer screen a few days ago in an e-mail.               SEC orders FINRA to improve compliance policies and procedures The SEC order arises from a whistleblower complaint.  Prior to submitting records to the SEC, the regional director of the FINRA Kansas City office had minutes of the district office staff […]