Comment Letters

FINRA Requests Comments on Proposal for Remote Inspections of Branch Offices

FINRA’s responded to industry feedback on the inspection process for branch offices.  Based on Rule 3110 (the Supervision Rule),  each firm to currently required to establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA … Continue reading FINRA Requests Comments on Proposal for Remote Inspections of Branch Offices

FINRA Comment Letter – Regulatory Notice 14-09; Limited Corporate Financing Broker (LCFB)

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 (Proposed Rule Set”) for member firms that meet the definition of “limited corporate financing broker” (LCFB).  It is a positive sign that FINRA acknowledges that … Continue reading FINRA Comment Letter – Regulatory Notice 14-09; Limited Corporate Financing Broker (LCFB)

SEC Comment Letter – JOBS Act – Crowdfunding

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 creation and economic growth, relying in part on provisions relating to securities offered or sold through “crowdfunding.” As a primary focus of The LeGaye Law … Continue reading SEC Comment Letter – JOBS Act – Crowdfunding

FINRA Comment Letter – Regulatory Notice 12-34 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 firms. The comments requested are directly related to recently passed legislation, The Jumpstart Our Business Startups Act (JOBS Act). The JOBS Act focused on increasing … Continue reading FINRA Comment Letter – Regulatory Notice 12-34 Crowdfunding

FINRA Comment Letter – Rule 5122 Member Participation in Private Placements

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 proposal to amend its rules governing member participation in private placements through a proposed amendment to FINRA Rule 5122 (Proposed Rule Amendment”). As stated by … Continue reading FINRA Comment Letter – Rule 5122 Member Participation in Private Placements

FINRA Comment Letter – Rule 2040 – Payments to Non-Registered Persons

FINRA Comment Letter – Rule 2040 – Payments to Non-Registered Persons On December 2,2009, the Financial Industry Regulatory Authority (FINRA) published Regulatory Notice 09-69 (Regulatory Notice) seeking comments on its proposal to amend its rules governing payments to unregistered persons through a proposed FINRA Rule 2040 (Proposed Rule).  As stated by FINRA in the Regulatory Notice, … Continue reading FINRA Comment Letter – Rule 2040 – Payments to Non-Registered Persons