On July 5, 2023, the D.C. Circuit Court of Appeals issued an injunction that raises a challenge to FINRA’s authority to use FINRA-appointed hearing officers to conduct enforcement proceedings. The injunction enables Alpine...more
The SEC’s pay-to-play rule has given advisers reason to worry about potential foot faults since its adoption. As we have noted in prior posts, the rule is filled with landmines and is therefore difficult to navigate. As was...more
The Securities and Exchange Commission adopted amendments to the financial responsibility requirements for broker dealers under the Securities Exchange Act of 1934 (Exchange Act) designed to safeguard customer securities and...more