New Title IX Regulations: A Seismic Shift During a Pandemic (Webinar Recording)
As the song goes, time keeps on slipping, slipping, slipping into the future. While Steve Miller may not have had FINRA and the SEC in mind when he wrote that lyric, the shoe certainly fits. Because here’s the thing about...more
Two Years Later, Regulation BI Remains a “Tremendous Priority” for FINRA - June 30th marked two years since the implementation of Regulation Best Interest (“Reg BI”) and the client relationship summary or Form CRS. Firm...more
FINRA, of course, has lots, and lots, of rules. Heck, it has rules about making rules. The things that RRs can and cannot do per those rules are strictly proscribed, mostly in great detail. Things that ordinary people can...more
Recent regulatory and enforcement developments - Hong Kong - Court rules on disclosure of disciplinary decisions- Accountants and other professionals should not expect that disciplinary decisions against them will remain...more
If you are a regular reader of this blog, you know that one of my pet peeves with FINRA is its unrelenting zeal to bar people, permanently, from the securities industry. Seemingly without much regard for the actual conduct at...more
While I feel I have enjoyed as much success defending respondents in FINRA Enforcement matters as anyone, I am still careful to caution clients who are unwilling to consider any settlement that going toe-to-toe with FINRA at...more
On January 29, 2019, the Public Company Accounting Oversight Board (PCAOB or “Board”) adopted amendments to its bylaws and rules that make the PCAOB’s appointment and removal of its hearing officers subject to the approval of...more
Many a school child has received the awful warning to be careful lest some offense be entered on his or her “permanent record”. As required by statute (15 U.S.C. § 78o-3(i)), the Financial Industry Regulatory Authority, Inc....more
Senators Charles Grassley (R-Iowa) and Jack Reed (D-Rhode Island) have re-introduced their proposal to open to the public disciplinary proceedings by the Public Company Accounting Oversight Board against accountants. Under...more
That is the question that the SEC has essentially posed for registered investment advisers in a National Exam Program Risk Alert. In doing so, the SEC has stated that it will be “examining compliance oversight and controls of...more
CME Group Reminds Members of Regulatory Requirements for EFRPs and Block Trades Through Disciplinary Actions: The CME Group brought and resolved multiple disciplinary actions against various members and non-members related to...more
The Corporate and Financial Weekly Digest edition of March 29, 2013 summarized the Financial Industry Regulatory Authority’s proposed rule change to amend Rule 8313, which governs the release of disciplinary and other...more
It is often said that bad things come in threes. I have often wondered where this phrase came from. ...more
The Financial Industry Regulatory Authority filed a proposed rule change to amend Rule 8313, which governs the release of disciplinary and other information by FINRA to the public. Among other things, amended Rule 8313 would...more
In October 2011, Charles Schwab ("Schwab") began inserting into its customer Account Agreements a class action waiver clause....more