FINRA Notice to Members 20-08

As mentioned last week FINRA has issued Notice to Members 20-08. Here are a few of the issues that it addresses. In Notice to Members 20-08 FINRA has granted relief to member firms as they try to navigate the COVID-19 pandemic. Most importantly is the ability to set up remote offices without having to make […]

Update Your Business Continuity Plan Today

Now is the time to pull out your Business Continuity Plan and read it. You need to make sure that all of the information is accurate. Have you changed the location of your offsite location? Have you changed the policy on people working from home? Is your communication tree up to date? If you do […]

FINDERS AND BROKERS: Who to pay?

Lately I have gotten a number of questions about raising capital for small companies. It usually starts with a question about someone who has good connections and believes that she can raise money for the company but wants to receive some type of compensation.

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 […]