Davison-Lawblog is back. As before I will provide practical legal and regulatory solutions to the ever growing regulatory issues that arise for broker-dealers and financial service firms. I am also interested in engaging with you and hope you will leave your comments.
I just posted on my blog Crowdfunding-lawblog.com , a look at possible differences between funding portals and broker-dealers as they function as intermediaries in the crowd.
Please follow this link for a Client Alert I wrote dealing with the JOBS Act and Research.
I have started a new Blog devoted to the developing crowdfunding industry. With the passage of the JOBS Act this once controversial concept has become a reality. Please add Crowdfunding LawBlog to your follow list. I will continue to focus on broker-dealers, investment advisers and funds on this blog.
If you had asked me a year ago if crowd investing would ever become law I would have told you absolutely not. There was no way Congress, which had been so hard on the regulators for allowing the Madoff disaster, would open the floodgate for all sorts of fraudulent activity. Never would Congress fall for […]
Earlier this week I told investment advisers CCOs not to lose sleep. I suggested that during this 45 day period until registration you should systematically review your compliance and supervisory policies and procedures. I missed the fun yesterday. Yesterday at the Investment Adviser Association Investment Adviser Compliance Conference Robert Plaze, Deputy Director of the SEC Division of Investment Management warned […]
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 […]
If you are the Chief Compliance Officer for a broker-dealer and a registered investment advisor keep reading. During 2011, one within the last month, the SEC has taken action against two dually registered broker dealer/investment advisers for failure to have adequate written supervisory policies and procedures, compliance manuals and code of ethics for the advisory […]
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 […]
Last week in my post on the Startup Exemption I wrote about hearings starting in Congress. Having reviewed the startup exemption proposal that is presently circulating on the Internet and reading some of the testimony from last week’s hearings I realize what the main problem it is not the concept of the startup exemption. It […]