Benjamin Coulter

Benjamin Coulter

Burr & Forman

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FINRA Rule 2040 Goes Into Effect

On August 24, 2015, FINRA Rule 2040 concerning payments to unregistered persons went into effect. The rule, approved by the SEC in January 2015, is aligned with § 15(a) of the Securities Exchange Act of 1934. Generally, FINRA...more

8/27/2015 - Broker-Dealer Compensation Agreements Compliance Financial Markets Financial Sector FINRA Foreign Affiliates No-Action Letters SEC Securities Exchange Act Unregistered Brokers

Reverse Churning: Don't Fall Asleep at the Wheel

It is obvious that broker-dealers and their registered representatives, and investment advisors, must be careful in making recommendations to clients. But the recent increase in regulatory interest relating to inaction in a...more

7/11/2014 - Broker-Dealer Fiduciary Duty FINRA Investment Adviser SEC

Burr Alert: FINRA Updates Guidance On Its Suitability Rule

In its Regulatory Notice 12-55, the Financial Industry Regulatory Authority ("FINRA") has updated its guidance on FINRA Rule 2111 concerning suitability. This is FINRA's fourth regulatory notice concerning the rule -- it...more

12/19/2012 - Broker-Dealer FINRA Investment Adviser Suitability Rule

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