New Blog

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.

I Miss All the Fun

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 […]

Don’t Just Wait!

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 […]

FINRA Fails to Furnish Complete and Accurate Records

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 […]