On April 30, 2024, FINRA proposed amendments its Maintaining Qualifications Program (“MQP”) to reopen the period in which certain participants can complete their prescribed 2022 and 2023 continuing education (“CE”)...more
In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more
FINRA, of course, has lots, and lots, of rules. Heck, it has rules about making rules. The things that RRs can and cannot do per those rules are strictly proscribed, mostly in great detail. Things that ordinary people can...more
UPDATE: As of December 30, 2020, Arizona, Arkansas, Michigan, and Rhode Island have joined Iowa in adopting the NAIC model rule for best interest standard in annuity sales. Alabama, Delaware, Kentucky, Maine, Nevada and Ohio...more
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
At the October 7, 2020 open meeting of the Securities and Exchange Commission (SEC), Chairman Jay Clayton announced that the Staff of the Commission proposed to grant exemptive relief, permitting natural persons to engage in...more
FINRA’s National Adjudicatory Counsel (“NAC”), recently, affirmed a disciplinary panel decision significantly sanctioning a broker-dealer for paying unregistered persons and entities. FINRA alleged, among other things,...more
While much of the broker-dealer world has been trying to figure out how to protect the financial welfare of their customers, in addition to watching Netflix and searching in vain for Lysol wipes online, our trusty securities...more
Regulation Best Interest: The Focus on Costs (Part 1) - The SEC has issued its final Regulation Best Interest (Reg BI), Form CRS Regulation, RIA Interpretation and Solely Incidental Interpretation. I am discussing the...more
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
A recent Securities and Exchange Commission (“SEC”) order imposed sanctions on a financial institution for failing to reasonably supervise a representative’s conduct. In its findings, the SEC highlights the institution’s...more
On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more
Lost in the commotion surrounding the Department of Labor's new fiduciary rule was the Securities and Exchange Commission's approval of FINRA's recruitment bonus disclosure rule, which requires action by broker dealers when...more
Recently, the SEC approved FINRA’s proposed new Rule 3110(e) relating to background investigations of registered persons. FINRA Rule 3110(e), which replaces NASD Rule 3010(e) and goes into effect on July 1, 2015, streamlines...more
Continuing its efforts to increase the amount of publicly available information on financial industry professionals, the Financial Industry Regulatory Authority (FINRA) announced last Wednesday its proposed plans to...more