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The Very Pricey Real Estate At The Intersection Of The Old Books-And-Records Rule And The New Reality Of How People Communicate

Happy New Year! I hope you had an enjoyable holiday season. At least happier than that of JP Morgan Securities, which, right before Christmas, got to write checks to the SEC and the CFTC totaling $200 million. That’s a...more

SEC Settlement Proves That It’s Easy Enough For An IA To Get In Trouble Just For Doing Nothing

My job frequently requires that I explain to someone – whether my client, an ALJ, an arbitration panel, even a regulator – the fundamental difference between a broker-dealer and an investment advisor. An IA operates pursuant...more

Securities America SEC Settlement Raises Prospect Of New Supervisory Standard

There have been tons of cases where firms got in trouble – in AML trouble, which is one the worst kinds of trouble – for failing to be sufficiently on top of third-party wires, i.e., where a customer wires money not to...more

Cetera Pays $1 Million To Settle A Case That Should Have Been Moot . . . Except FINRA Failed To Act On A Wildly Popular Rule...

Almost three years ago, in Reg Notice 18-08, FINRA wisely (but, nevertheless, still a bit late to the party) proposed to revise its own prior guidance regarding the troublesome intersection between outside business activities...more

SEC Settlement Proves That When CCOs Spot A Problem, Silence Is Not Golden

A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more

The (Possible) Benefit Of Self-Reporting And Internal Discipline

Historically, one of the surest ways to get yourself permanently barred from the industry is to forge a customer’s signature on something. According to the pertinent Sanction Guideline, at a minimum, a forgery, that is, a...more

FINRA AWC Provides New Defense To Allegation Of “Willfulness”

I dare you. In fact, I double-dog dare you to figure out how or why FINRA decides to charge willfulness in some cases but not in others. Bottom line is that it is nearly impossible (except if you’re a big firm, in which case...more

FINRA AML Settlements Drive Home The Point: When It Comes To Supervision, Actions Speak Louder Than Words

The longer I do this, the more apparent it becomes just how little anything changes. Sure, some things do change, a little. Rule numbers may get updated, as Rule 2310 becomes Rule 2111. Things that once may have been done...more

When It Comes To Sanctions, What Does “Relevant Disciplinary History” Mean To FINRA, And Does It Vary Depending On The Size Of The...

The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a...more

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