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Professional Disciplinary Actions Investment Adviser

UB Greensfelder LLP

Time Never Matters To Regulators, Until It Does

UB Greensfelder LLP on

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

UB Greensfelder LLP

If You Supervise Yourself - Which You Cannot Do - Make Sure You Do It Right

UB Greensfelder LLP on

I have always operated with the understanding that, per FINRA rules, one cannot supervise him- or herself. Hardly an outrageous proposition. Today, however, that fundamental, bedrock understanding was so shaken, it has left...more

UB Greensfelder LLP

FINRA AWC Provides New Defense To Allegation Of “Willfulness”

UB Greensfelder LLP on

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

Vedder Price

OCIE Issues Risk Alert Relating to Investment Adviser Oversight of Supervised Persons with Disciplinary Histories

Vedder Price on

On July 23, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its observations and recommendations following an examination initiative that focused on oversight practices...more

UB Greensfelder LLP

Does FINRA Have Jurisdiction Over Me?

UB Greensfelder LLP on

Does FINRA have jurisdiction over me? This is a question that I regularly field at the outset of regulatory engagements. My answer differs depending on a number of factors, including the nature of a person’s role and duties...more

Sheppard Mullin Richter & Hampton LLP

Recent Development in Regulatory Enforcement of Digital Securities

In a flurry of activity and confluence of developments, the SEC, FINRA and a Brooklyn federal judge have commenced actions and made rulings that continue to define the regulatory framework and obligations surrounding the sale...more

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