I have been busy the last month getting ready for a big arbitration, and attending the first week of what looks like is going to be a four- or five-week slog when all is said and done. So, I am just catching up on some recent...more
4/17/2019
/ Broker-Dealer ,
Civil Monetary Penalty ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Internal Investigations ,
Market Manipulation ,
Penny Stocks ,
Policies and Procedures ,
Professional Misconduct ,
Registered Representatives ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Transactions ,
Securities Violations
If you are a regular reader of this blog, then you know that over my last few posts, I have been talking about an increasingly visible effort by FINRA to turn its regulatory eye from rogue brokers – who have been an irritant...more
I told you two weeks ago in my blog post that this would happen. I told you that when Robert Cook announced the topics to be taken up at the February/March FINRA Board meeting in Boca Raton, he slipped and used the new phrase...more
On February 26, 2019, FINRA sent a seemingly innocuous memo to member firms giving a brief outline of the subjects that its Board will take up at its meeting this week in sunny Boca Raton, Florida. (Wait, the Board isn’t...more
I have been waiting for a while to write about this issue, since it arose in an Enforcement case I handled for a client, and I wanted the matter to run its full course at FINRA before I started throwing stones. Sadly, there...more
2/19/2019
/ Attorney-Client Privilege ,
Computer Hard Drives ,
Discovery ,
Discovery Disputes ,
Electronically Stored Information ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
FINRA Hearing Panel ,
Motion to Compel ,
Search Warrant ,
Subpoenas
The securities industry’s concern over the aging of the U.S. population, specifically, aging investors, has, apparently, reached a fever pitch. On February 5th in New York, SIFMA hosted its “Senior Investor Protection...more
About a year ago, the SEC offered investment advisors the unique opportunity to report themselves to the SEC if they sold mutual funds to their clients that offered a lower priced share class than the class actually selected...more
1/31/2019
/ 529 Plans ,
Broker-Dealer ,
Conflicts of Interest ,
Deadlines ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Mutual Funds ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Self-Reporting ,
Settlement Negotiations ,
Share Class Selection Disclosure Initiative (SCSD) ,
Share Classes
In what has become an annual, but hardly exciting – I mean, it’s not like anxiously awaiting the day that pitchers and catchers report to Spring Training – tradition, with the turning of the calendar to the new year, FINRA...more
What exists at the point where PIABA’s transparent self-interest in getting paid and FINRA’s historical lack of transparency about who is actually driving its agenda regarding arbitrations? This: a late December decision by...more