The SEC has sent the FINRA propose rules for capital acquisition brokers out for comment. Comments are due on April 13, 2016. As you may remember these rules are the outcome of the No-Action letter previously issued by the SEC relating to the registration of a finder as a broker-dealer. Under the proposed rules capital […]
As it does every year FINRA has published its Regulatory and Examination Priorities Letter. This year it is focused on three broad issues: Culture, Conflict of Interest and Ethics Supervision, Risk Management and Control Liquidity FINRA and its predecessor entities have always talked about “firm culture”. But this year they have given it a definition: […]
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.
So are we to understand that regulation is a good thing and necessary to protect investors in the crowd? Well it appears so. On March 23, 2012, at 2:29 p.m. EDT Marketwire issued a press release announcing the creation of the Crowdfund Intermediary Regulatory Association (CFIRA). Its mission is to provide investors “protection and market […]
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 […]