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FINRA’s Important Reminder to Firms—Don’t Forget to Supervise Third-Party Vendors

I. Overview - Broker-dealers, like most companies, rely on third-party vendors for a wide variety of functions. This common practice of outsourcing does not relieve a broker-dealer of its regulatory compliance and...more

New Year, Old Problem: Broker-Dealers Should Evaluate Their Supervision of Personal Device Use

Many companies that transitioned to a work-from-home environment in early 2020 may have reasonably anticipated a return to the normalcy of in-office operations by the end of the year. Yet as 2021 commences, remote work has...more

Another Cop on the Beat? CFP Board Signals Increased Enforcement Focus

Financial advisors have long used the Certified Financial Planner designation as an indicator to potential clients that they meet high standards of professionalism and ethics within their field. The Certified Financial...more

Ready or Not, Prepare to Start Answering Questions About Reg BI Compliance

On June 5, 2019, the SEC adopted Regulation Best Interest (“Reg BI”), which requires broker-dealers and associated persons to make recommendations regarding securities transactions (or investments involving securities) that...more

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

Recent New Jersey Rule Proposal Progresses State Efforts to Impose Fiduciary Duties on Brokers

On April 15, the New Jersey Bureau of Securities (the “Bureau”) issued a rule proposal to establish a uniform fiduciary duty standard applicable to investment advisers, brokers-dealers and their registered representatives and...more

FINRA Regulatory Notices Demonstrate Focus on Excessive Trading, Supervision

While the securities industry focused on parsing the Securities and Exchange Commission’s recently proposed best-interest standard and speculating about the ultimate fate of the Department of Labor’s vacated fiduciary rule,...more

FINRA Enforcement: New Direction for the Regulator

With new leadership at the helm of the Financial Industry Regulatory Authority (FINRA), the broker-dealer industry’s primary self-regulator, and the FINRA Enforcement Department, there is an opportunity for real and...more

FINRA Proposes Transformative Rule on Outside Business Activities

On Feb. 26, the Financial Industry Regulatory Authority issued Regulatory Notice 18-08 seeking comment on a proposed new rule to address outside business activities of registered persons. The proposal, a result of FINRA’s...more

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