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 […]

SEC Chair Asserts Authority Over the Staff

  SEC Chair, John Clayton, issued a statement on September 14, 2018, that on its face should not have caused any concern. We have always known that the Commission oversees the work of the staff and that an individual staff member cannot bind the Commission. We know that No-Action letters are not binding although we […]

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 […]