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 […]
On June 5, 2019, the SEC on a 3 to 1 vote approved Regulation Best Interest. This regulation is the SEC’s attempt to align broker-dealers with the fiduciary rule that governs investment advisers. It has been a long-held belief that broker-dealers have internal conflicts because they sell products that are packaged by affiliates and sell […]
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 […]
The world seems to be in a state of complete chaos. But if you are a Chief Compliance Officer of a broker-dealer or investment adviser you may have noticed that the SEC and FINRA have not let all of the chaos alter their focus. Deregulation has not set in with either body. So for […]
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 […]
Every year at about this time, I like many other securities attorneys write a post about the examination priorities letters that are issued by the SEC and FINRA. From year to year the emphasis may change slightly but usually we know what the priorities will be. This year many thought the letters might change. FINRA […]
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