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 […]
As I wrote earlier this week, follow your regulators during this time of the coronavirus. FINRA has issued this notice. Regulatory Notice 20-08.
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, 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 […]
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 […]
While we were off enjoying the 4th of July in the middle of the week, FINRA was issuing Regulatory Notice 18-20—Digital Assets. It is short and seemingly rather innocent. But read it closely. A few weeks ago some FINRA members were contacted by their Regulatory Coordinators and asked if they were doing anything with digital […]
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 […]
We are in the fourth full day of the administration of the 45th President. During the campaign he made a lot of promises. One was to reduce regulation. There were not a lot of specifics, but his nominations for cabinet positions would indicate that regulatory reduction is on the way. How is the reduction in […]
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 […]
On June 1, 2016, the SEC issued an Administrative Order (SEC 34-77959, 40-4411) against BlackStreet Capital Management, LLC. At the highest level this was a disclosure case. I am however, going to focus on just one of the violations. The SEC found that: In connection with the acquisition and disposition of portfolio companies or their […]
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