On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a...more
On March 17, 2022, FINRA issued Regulatory Notice 22-10 (“Notice”), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (“CCO”). The Notice...more
I am reluctant to wade into the issue of CCO liability because I gravitate toward a simplistic answer to a complex question – when does a CCO cross the line to warrant civil or even criminal prosecution? My simplistic...more
While undoubtedly FINRA will be issuing its annual “examination priorities” letter any day now, that is hardly the best way to figure out exactly what FINRA is paying attention to now (as that letter kind of reads the same,...more
On October 20, 2020, a consortium of U.S. federal financial regulators (Regulators), issued a proposed rule (Proposed Rule) that, if enacted, would codify that mere supervisory guidance that is not the product of notice and...more
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more