In the on-going evolution of the fight against cyber-security threats, broker-dealers and investment advisers need to have robust cyber-security policies and procedures. One of the initial steps is to think … Continue reading Cyber-Security Procedures and Data Classification
The Financial Industry Regulatory Authority (FINRA) announced that it has fined Oppenheimer & Co. Inc. $2.25 million and ordered the firm to pay restitution of more than $716,000 to affected … Continue reading Oppenheimer Fined 2.25 million for ETF Suitability & Due Diligence Failures
The Financial Industry Regulatory Authority (FINRA) announced at its recent 2016 Annual FINRA Conference in Washington DC that it has created a Cybersecurity Checklist to assist small member firms in establishing … Continue reading FINRA Issues Small Firm Cybersecurity Checklist
The U.S. Securities and Exchange Commission (“SEC”) has recently announced whistleblower awards to four individuals who provided the SEC with information in three ongoing investigations. The SEC announced on May 13, 2016 … Continue reading Three Whistleblower Awards Issued By SEC
The Securities and Exchange Commission (“SEC”) has issued Compliance and Disclosure Interpretations (C&DIs) providing interpretive guidance on Regulation Crowdfunding, which became effective May 16. The C&DIs answer a number of … Continue reading Crowdfunding Guidance Released by SEC
FINRA executives have been speaking regularly about conflicts of interest, firm culture and professional ethics. Firm cultural values have a profound influence on how a broker-dealer conducts its business, including … Continue reading Creating & Articulating Firm Culture For FINRA
The Securities and Exchange Commission’s (“SEC”) Advisory Committee on Small and Emerging Companies met on May 18 and focused primarily on the proposed changes in the definition of an accredited investor. During … Continue reading Changes in Accredited Investor Definition on Horizon
The Securities Industry and Financial Markets Association (SIFMA) recently released its annual U.S Securitization Year in Review report. The report offers a consolidated review of the U.S securitization markets in … Continue reading SIFMA releases 2015 Securitization Year in Review
The Securities and Exchange Commission approved the adoption of FINRA Rule 2242 (Debt Research Analysts and Debt Research Reports) to address conflicts of interest relating to the publication and distribution … Continue reading Implementation Date of FINRA Rule 2242 Extended to July 16, 2016
The Financial Industry Regulatory Authority (“FINRA”) has proposed the creation of a separate rule set that would apply to firms that meet the definition of a ‘‘capital acquisition broker’’ (“CAB”) and … Continue reading Comment Period Ends May 6, 2016 on the Proposed Capital Acquisition Broker Rules
The SEC approved Regulatory Notice 15-34, the adoption of FINRA Rule 2272 (Sales and Offers of Sales of Securities on Military Installations), to govern sales and offers of sales of securities … Continue reading SEC Approves FINRA Rule 2272 on the Sales of Securities on Military Installations
Since early last year, the Securities Industry and Financial Markets Association(“SIFMA”) and the Investment Company Institute (“ICI”) have publicly supported the shortening of the settlement cycle from trade date plus three … Continue reading The Pressure to Shorten the Settlement Cycle From T+3 to T+2 Has Increased
FINRA maintains contact information records of all Executive Representatives, Chief Compliance Officers and other individuals at firms, including contacts that are required under FINRA rules and By-Laws, and others that … Continue reading FINRA Designates Chief Information Security Officer as New Role
In her opening remarks at the annual “SEC Speaks” conference held in Washington, D.C., the U.S. Securities and Exchange Commission (“SEC”), SEC Chairman Mary Jo White cautioned that the SEC … Continue reading Upshot of SEC’s 2016 Goals – Active Year for Regulatory Rulemaking
The Securities and Exchange Commission announced that starting on Feb. 16, 2016, the fee rates applicable to most securities transactions will be set at $21.80 per million dollars. Consequently, each … Continue reading SEC Announces its Fee Rate Advisory for Fiscal Year 2016
The Financial Industry Regulatory Authority (“FINRA”) has announced a proposed new set of rules that address the needs of FINRA member firms that are solely corporate financing firms that advise … Continue reading FINRA Proposes New Registration Category for Corporate Financing Brokers
The Financial Industry Regulatory Authority, Inc. (“FINRA”) has filed a proposed rule change to adopt FINRA Rules 2030 (Engaging in Distribution and Solicitation Activities with Government Entities) and 4580 (Books … Continue reading FINRA Proposes “Pay-To-Play” Rules
The Securities and Exchange Commission released its Office of Compliance Inspections and Examinations’ (OCIE) 2016 exam priorities. New areas of focus include liquidity controls, public pension advisers, product promotion, and two popular investment … Continue reading SEC Releases the 2016 Examination Priorities
The Financial Industry Regulatory Authority (FINRA) announced in Regulatory Notice 15-50 that the Securities and Exchange commission approved amendments to FINRA Rule 2210 (Communications with the Public) that become effective … Continue reading FINRA Rule 2210 Amended to Require BrokerCheck Website Hyperlink
The Financial Industry Regulatory Authority (FINRA) has fined Scottrade, Inc. $2.6 million for failing to retain a large number of securities-related electronic records in the required format, and for failing … Continue reading Firm Fined $2.6 Million for Failures in Electronic Records and Email Retention
Moody’s Investors Services recently noted that In today’s interconnected and digital world, business leaders must be aware of the diverse cyber threats their business faces and be proactive in protecting … Continue reading Moody’s to consider CyberDefense in its Credit Ratings
The Securities and Exchange Commission (SEC) announced a series of enforcement actions against lawyers across the country charged with offering EB-5 investments while not registered to act as brokers. In one … Continue reading Lawyers Tagged by SEC for Offering EB-5 Investments as Unregistered Brokers
The Financial Industry Regulatory Authority, Inc. (“FINRA”) has filed with the Securities and Exchange Commission (“SEC”) a proposed rule change to adopt Funding Portal Rules 100, 110, 200, 300, 800, … Continue reading FINRA Proposes Amendments to the Funding Portal Rules
FINRA’s experience with its Securities Helpline for Seniors has highlighted issues relating to financial exploitation of this group of investors. Among these issues is a firm’s ability to quickly and … Continue reading Comment Period is Open on FINRA’s Proposed Rule Amendments to Address the Financial Exploitation of Seniors
Richard Ketchum, Chairman and CEO of the Financial Industry Regulatory Authority (FINRA), shared his thoughts on the top 3 regulatory concerns for 2016 recently at the SIFMA Annual Conference. His … Continue reading FINRA’s Top 3 Regulatory Concerns for 2016 Examination Focus
The Financial Industry Regulatory Authority (FINRA) has announced the U.S. Securities and Exchange Commission’s (SEC) recent approval of FINRA’s proposal to expand its transparency initiative for over-the-counter (OTC) equity securities. … Continue reading FINRA Rule to Increase Transparency in OTC Equities Market
The Securities and Exchange Commission (SEC) charged a New York-based investment adviser and its affiliated distributor with improperly using mutual fund assets to pay for the marketing and distribution of … Continue reading SEC Charges Investment Adviser With Improperly Using Mutual Fund Assets to Pay Distribution Fees
Two agencies approved a final rule that will govern how much money financial firms must set aside in derivatives deals. A key change from recent draft versions of the rule … Continue reading FDIC Approval of Margin Rules Triggers SEC Parallel Rule
The Securities and Exchange Commission (SEC) has adopted final rules to permit companies to offer and sell securities through crowdfunding. Crowdfunding is an evolving method of raising capital that has … Continue reading Final Crowdfunding Rules Adopted by the SEC
The Securities and Exchange Commission (“SEC”) recently published the Private Funds Statistics Report for Fourth Quarter 2014. The report provides private fund industry statistics and trends, reflecting aggregated data reported … Continue reading SEC Publishes Private Funds Statistics Report
FinCEN has issued the second edition of SAR Stats, FinCEN’s annual review of aggregated Suspicious Activity Report (SAR) filing activity and announced the introduction of Interactive SAR Stats. FinCEN developed … Continue reading FinCen Releases Annual Review of SAR’s Data
FINRA recently published Regulatory Notice 15-32 to provide guidance regarding the FINRA filing requirements and review procedures that apply to firms that participate in Regulation A+ offerings. Specifically, FINRA’s Corporate Financing Rules … Continue reading FINRA Provides Guidance on Regulation A+ Offerings
The Financial Industry Regulatory Authority (FINRA) ordered 12 firms to pay restitution totaling more than $4 million and fines totaling more than $2.6 million for failing to apply available sales … Continue reading FINRA Targets Firms for Failing to Apply Sales Charge Discounts
In light of both the targeted sweep exams the expanded exam modules of the SEC, FINRA and state securities regulators on cybersecurity, and recent enforcement actions related to cyber breaches, it … Continue reading Cybersecurity Best Practices for Broker-Dealers and Advisers for 2015
The Securities and Exchange Commission announced enforcement actions against 22 municipal underwriting firms for violations in municipal bond offerings. The actions are the second round of filings against underwriters under … Continue reading SEC Sanctions Underwriting Firms for Fraudulent Municipal Bond Offerings
In April 2014, the Financial Industry Regulatory Authority (“FINRA“) rolled out the CRD Public Records Validation Initiative to conduct a review of public records available for the entire population of … Continue reading CRD Public Records Validation Initiative Evolving to Ongoing Validation
The Securities and Exchange Commission (SEC) recently approved amendments to the Financial Industry Regulatory authority (FINRA) rules that lower the evidentiary standard to impose a temporary cease and desist order … Continue reading FINRA Rules Amended to Expedite Cease and Desist Orders
The North American Securities Administrators Association (“NASAA”) formally adopted a Model State Rule which, if adopted by each state, will exempt M&A Brokers from having to register as securities brokers … Continue reading NASAA Adopts Model M&A State Rule
Every two years, state securities examiners voluntarily report sample data from their investment adviser examinations to the North American Securities Administrators Association’s (NASAA) Investment Adviser Operations Project Group. The 2015 … Continue reading State Exam Programs Reflect Improved Compliance by State Regulated Advisers
The Financial Industry Regulatory Authority (FINRA) announced that its Board of Governors approved a rulemaking item to help firms better protect seniors and other vulnerable adults from financial exploitation. The … Continue reading FINRA Board Approves Rulemaking Item to Protect Seniors
The Securities and Exchange Commission (SEC) announced that R.T. Jones Capital Equities Management, a St. Louis-based investment adviser, has agreed to settle charges that it failed to establish cybersecurity policies … Continue reading SEC Sanctions Investment Adviser $75,000 for Cyberattack
The Financial Industry Regulatory Authority (FINRA) announced that as a result of a 2014 onsite exam, it found securities violations including various misleading sales pitches, customer account churning and other … Continue reading FINRA Cracksdown on Broker Migration
The Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) has issued an additional Risk Alert regarding the Targeted Industry Reviews and Examinations Initiative for the second round of cybersecurity … Continue reading SEC Exam Program Doubles Up Focus on Cybersecurity
The Municipal Securities Rulemaking Board (MSRB) has filed a Notice of Rule Change with the Securities and Exchange Commission (SEC) to apply the limitations on business-related gift-giving that currently applies to … Continue reading MSRB Seeks Approval to Amend Gifts Rule
The Securities and Exchange Commission is warning brokerages to better monitor the sales of risky complex investments to their retail clients. In a recently issued National Exam Program Risk Alert, … Continue reading SEC to Broker-Dealers: Better Supervise Sales of Risky Products
The Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2015-13 that it will be raising the fees assessed to its registrants (brokers, dealers, and municipal securities dealers (collectively “dealers”) … Continue reading MSRB to Raise Annual and Initial Fees
Financial Industry Regulatory Authority, Inc. (“FINRA”) has filed a proposed rule change with the Securities and Exchange Commission (“SEC”) to adopt NASD Rule 3040 (Private Securities Transactions of an Associated … Continue reading FINRA Proposes to Adopt FINRA Rule 3280 – Private Securities Transactions
The Securities and Exchange Commission (SEC) approved the adoption of FINRA Rule 2241 ( Research Analysts and Research Reports), a consolidated rule to address conflicts of interest relating to the … Continue reading SEC Approves Rule Addressing Conflicts of Interest in Research Reports
FINRA recently issued a Targeted Exam Letter that is focused on conflicts of interest with respect to compensation practices for retail brokerage firms. As noted in FINRA’s Annual Priorities Letter, conflicts of … Continue reading FINRA Issues Targeted Exam Letter: Compensation Conflicts of Interest Review
The Basel Institute on Governance recently published the Basel Anti-Money Laundering (AML) AML Index for 2015. The report provides an annual risk rating of money laundering and terrorist financing by ranking countries … Continue reading Basel Institute Publishes the 2015 Basel AML Index
The Financial Crimes Enforcement Network (FinCEN) has finally reproposed a rule requiring investment advisers that are required to be registered with the U.S. Securities and Exchange Commission (SEC) to establish … Continue reading AML Programs to be Required for Federal Investment Advisers
The State of Texas sanctioned Citigroup Global Markets Inc. for failure to monitor the registration status of sales assistants, some of whom accepted client orders without being appropriately licensed. Texas was part of … Continue reading State Regulators Jump on Bandwagon of Sanctioning Wall Street Brokerages
The Securities and Exchange Commission has finally adopted the final rule t requiring public companies to disclose the ratio of the compensation of its chief executive officer (CEO) to the median … Continue reading SEC Adopts Rule for Pay Ratio Disclosure
On August 6, 2015, the Securities and Exchange Commission (SEC) issued a No Action Letter to Citizen VC, Inc. (CVC) that appears to have further loosened the prior No Action … Continue reading Substantive Pre-Existing Relationships Possible in On-Line Private Placements
FINRA issued Regulatory Notice 15-27 to remind firms engaging in municipal securities transactions that their written supervisory procedures should identify the process for detecting, resolving and preventing the consequences of firm short positions … Continue reading FINRA Issues Guidance Relating to Firm Short Positions & Fails-to-Receive in Municipal Securities
The Securities and Exchange Commission (“SEC”) adopted Rule 206(4)-5 (“Pay to Play Rule”) under the Investment Advisers Act of 1940 in 2010. The Pay to Play Rule prohibited investment advisers … Continue reading Pay to Play Ban on Third-Party Solicitation Now Effective
The Securities and Exchange Commission (“SEC”), has approved the adoption of new FINRA Rule 2242 (Debt Research Analysts and Debt Research Reports) to address conflicts of interest relating to the publication and … Continue reading SEC Approves New FINRA Debt Research Analysts & Report Rules
The Financial Industry Regulatory Authority, Inc. (“FINRA”) has filed a proposed rule change to amend FINRA Rule 2210 (Communications with the Public) with the Securities and Exchange Commission (“SEC”). The proposed … Continue reading FINRA Proposes Change to Rule 2210 (Communications with the Public)
FINRA has extended the deadline to complete the 2015 Risk Control Assessment Survey(RCA) to July 31, 2015. The RCA is a survey that FINRA uses to better understand the business activities in … Continue reading FINRA Extends Deadline for 2015 Risk Control Assessment
The Securities and Exchange Commission (“SEC”) announced a whistleblower award of more than $3 million to a company insider whose information helped the SEC crack a complex fraud. The multi-million … Continue reading SEC Awards Whistleblower Over $3 Million Award
In her opening remarks at the 2015 National Compliance Outreach Program for Broker-Dealers SEC Chair Mary Jo White set the tone for the program, and addressed a number of issues. Most significant was her attempt … Continue reading SEC Chair Mary Jo White Sets the Tone at the Top
Oregon has joined California, Colorado, Connecticut, Delaware, Georgia, Hawaii, Illinois, Maryland, Massachusetts, Minnesota, Nebraska, New Jersey, New Mexico, Rhode Island, Vermont, Virginia and Washington, D.C. in the “Ban the Box” … Continue reading The Impact of “Ban the Box” Legislation on FINRA Broker-Dealers
Senators Jack Reed (D-RI) and Chuck Grassley (R-IA) introduced bipartisan legislation in the Senate to give the Securities and Exchange Commission (SEC) another tool to crack down on violations of securities laws … Continue reading Bill Introduced to Significantly Increase SEC Penalties
The SEC Office of Compliance Inspections and Examinations (OCIE) recently issued a Risk Alert regarding the Targeted Industry Reviews and Examinations Initiative related to retirement accounts. The Risk Alert noted … Continue reading SEC Launches Retirement Targeted Exam Initiative
In April 2014, FINRA announced it would conduct a review of public records available for the entire population of approximately 630,000 active registered representatives (RRs) for financial disclosures that may … Continue reading CRD Public Records Validation Initiative
FINRA is requesting comments in Regulatory Notice 15-22 on a revised proposal to adopt the NASD and Incorporated NYSE rules regarding discretionary accounts and transactions as FINRA Rule 3260 (Discretionary … Continue reading FINRA Requests Comments on Revised Proposal Regarding Discretionary Accounts
The Code of Arbitration Procedure for Customer Disputes (Customer Code) and the Code of Arbitration Procedure for Industry Disputes (Industry Code) (together, codes) govern the payments that FINRA makes to … Continue reading SEC Approves Amendments to the Codes of Arbitration Procedure to Increase the Fees Assessed for Late Cancellation or Postponement of a Hearing
The SEC announced on July 1, 2015 that Deloitte & Touche LLP (Deloitte) was charged by the SEC with violating auditor independence rules when its consulting affiliate, Deloitte Consulting LLP, maintained a … Continue reading Deloitte & Touche Charged With Violating Auditor Independence Rules
Based upon a public statement issued by SEC Commissioner Michael S. Piwowar and Commissioner Kara M. Stein earlier this week, it appears that that the plan to move from a three-day … Continue reading T+2 Trade Settlement on Regulatory Horizon
The U.S. Department of the Treasury (“Treasury Department”) submitted its Semiannual Regulatory Agenda for review by The Office of Management and Budget (“OMB”) in April 2015. The semiannual regulatory agenda … Continue reading FinCEN Re-Proposes AML Rule for Investment Advisers
The last 18 months has found the financial industry in the spotlight for cybersecurity breaches, and as a result, the SEC and FINRA are ramping up their expectations regarding cybersecurity for … Continue reading Financial Industry Cybersecurity Standards Not Modeled After Government Agencies, Thankfully …
The Municipal Securities Rulemaking Board (MSRB) is requesting comment on a proposal to modify the application of the standard of independence for the one public member of its Board of Directors … Continue reading MSRB Requests Comments on Alternative Standard of Independence for Investor Representative on its Board
FINRA’s announced a new ad campaign that is meant to underscore the ease and importance of checking BrokerCheck before investing. In tangent with the print ad released, FINRA plans to … Continue reading FINRA Launches National Ad Campaign
SIFMA’s Economic Advisory Roundtable has issued its semiannual survey of concerning the U.S. economic outlook and rates forecasts. For a summary of the survey and access to the full survey, Click Here.
The SEC is asking for comments on how new and novel exchange-traded products should be listed, marketed and traded, as part of an effort to potentially write new rules for the … Continue reading SEC Requests Comments on Exchange-Traded Products
FINRA has requested comments in Regulatory Notice 15-20 on a concept proposal to restructure the current representative-level qualification examination program into a format whereby all potential representative-level registrants would take a … Continue reading FINRA Requests Comments Proposal to Restructure the Representative-Level Qualification Examination Program
FINRA, through the The National Adjudicatory Council (NAC), first published the Sanction Guidelines in 1993. The goal of the Sanction Guidelines was twofold. First, it was intended to familiarize FINRA … Continue reading FINRA Enforcement Sanctions Increased
It appears that the proposed fiduciary rule submitted by the Department of Labor to the Office of Management and Budget is being fast-tracked and may be released today. Megan Leonhardt … Continue reading DOL Fiduciary Rule To Be Released As Early As April 14, 2015
FINRA Notice to Members 15-07 noted that the effective date of Rule 0190 is August 24, 2015. Rule 0190 is based largely on NASD IM-2420-1(a) (Transactions Between Members and Non-Members; … Continue reading FINRA Rule 0190 Effective August 24, 2105
Daniel LeGaye, Managing Partner of the LeGaye Law Firm PC, was quoted in a March 17, 2015 article on the broadening impact on the on-boarding precess of financial firms that … Continue reading LeGaye Law Firm Quoted: Article on Client On-Boarding
National Society of Compliance Professionals Panel Information Date: Tuesday, October 21, 2014 Time: 2:00PM – 3:PM Where: Gayload National Harbor Resort & Convention Center Session 2b BD Conflicts of Interest Conflicts … Continue reading 2014 NSCP National Conference – Washington, DC
2014 SILA National Education Conference – Anaheim, CA General Session – Cyber Security & Data Protection
The FINOP Exchange Announces a Virtual Presentation on Cybersecurity in the Financial Industry by presents virtual cybersecurity. Daniel LeGaye & Michael Schaps of The LeGaye Law Firm will focus on … Continue reading The LeGaye Law Firm Delivers Cybersecurity Presentation
It appears that the Financial Industry Regulatory Authority (“FINRA“) intends to back away from their reliance on FINRA Rule 8210 (the “Rule”) information requests for routine matters. At the Ask FINRA … Continue reading FINRA Backing Away From Reliance on Rule 8210 for Routine Information Requests
FINRA Comment Letter – Regulatory Notice 14-09; Limited Corporate Financing Broker (LCFB) The Financial Industry Regulatory Authority (FINRA) published Regulatory Notice 14-08 (Regulatory Notice) seeking comments on a proposed rule set … Continue reading FINRA Comment Letter – Regulatory Notice 14-09; Limited Corporate Financing Broker (LCFB)
National Society of Compliance Professionals Panel Information Date: Thursday, April 10, 2014 Time: 11:30 – 12:30 Where: Haynes and Boone, LLP, 2323 Victory Avenue, Suite 700, Dallas, Texas 75219 Session … Continue reading 2014 NSCP Southern Regional Meeting – Dallas
In what appears to be a noteworthy departure from the Securities and Exchange Commission’s (“SEC”) long-held view that persons receiving transaction-based compensation in connection with facilitating the acquisition and or … Continue reading M&A Brokers Exempted From SEC Broker-Dealer Registration
The LeGaye Law Firm is happy to announce that they have joined Patten Training and Review’s FINOP Exchange. The FINOP Exchange provides networking opportunities for CFOs and FINOPs of broker-dealer … Continue reading LeGaye Law Firm joins FINOP Exchange
Historically, the enforcement actions brought by the Securities and Exchange Commission (“SEC”) have focused more on fraud and misrepresentation, than books and records violations and not on compliance professionals. It appears … Continue reading SEC Enforcement Agenda Looks to Minor Rule Violations
An article by Daniel LeGaye of the LeGaye Law Firm titled “New Regulatory Guidance for Business Continuity Planning” was cited in a Blog titled “Preparing for disaster: Strategies for extending … Continue reading The LeGaye Law Firm Cited in Blog on Business Continuity
National Society of Compliance Professionals Panel Information Date: Thursday, March 11, 2013 Time: 10:15am – 11:30am Where: Alston + Bird LLP, Atlantic Center Plaza, 1180 West Peachtree St., Atlanta Ga … Continue reading 2013 NSCP Southern Regional Meeting – Atlanta
SEC Comment Letter – JOBS Act – Crowdfunding Set forth below are our comments related to Title III of the JOBS Act. The JOBS Act focused on increasing American job … Continue reading SEC Comment Letter – JOBS Act – Crowdfunding
FINRA Comment Letter – Regulatory Notice 12-34 Crowdfunding The Financial Industry Regulatory Authority (FINRA) published Regulatory Notice 12-34 (Regulatory Notice) seeking comments on proposed regulation of Crowdfunding Activities by FINRA member … Continue reading FINRA Comment Letter – Regulatory Notice 12-34 Crowdfunding
ERISA Section 408(b)(2) Fee Disclosures Are Due 6/30/2012 ERISA Section 408(b)(2) This is a reminder that all covered service providers to ERISA qualified plans (“ERISA Plan”) are required to deliver a fee … Continue reading ERISA Section 408(b)(2) Fee Disclosures Due 6/30/2012
John F.Roth, SEC SEC Compliance, Regional Center Selection, posted a blog posted titled “Securities Law and Finder’s Fees in the EB-5 Field”, in which The LeGaye Law Firm’ s article … Continue reading The LeGaye Law Firm Cited in Article
National Society of Compliance Professionals Panel Information Date: Thursday, April 11, 2011 Time: 3:45 – 5:00 Where: The Belo Mansion & Pavilion, 2101 Ross Avenue, Dallas, Texas 75201 BD Ethics – Code … Continue reading 2011 NSCP Southern Regional Meeting – Dallas
FINRA Comment Letter – Rule 5122 Member Participation in Private Placements On January 11, 2011, the Financial Industry Regulatory Authority (FINRA) published Regulatory Notice 11-04 (Regulatory Notice) seeking comments on its … Continue reading FINRA Comment Letter – Rule 5122 Member Participation in Private Placements
Compliance Date for Delivery to Clients of the New Form ADV Part 2B Supplements Extended by SEC As a result of the efforts of the Securities Industry and Financial Markets … Continue reading Compliance Date for Form ADV Part 2B Extended by SEC
Department of Labor Imposes Significant Disclosure Obligations On Broker-Dealers and Investment Advisers The Department of Labor (“DOL”) recently issued interim final regulations under Section 408(b)(2) (the “Rule”) of … Continue reading DOL Imposes Disclosure Obligations
The Securities and Exchange Commission’s (SEC) position on the payment of finder’s fees to non-registered broker-dealers has been further clarified in a request for a No-Action Letter, which was denied … Continue reading SEC Further Limts Use of Finders Fees