Payroll Protection Program (PPP) Loans Recent guidelines issued by the Securities and Exchange Commission (SEC) have again shed light on the fact that broker-dealers and investment advisers address disclosure issues differently. Specifically, the Payroll Protection Program (PPP), which was established pursuant to Section 1106(b) of the Coronavirus Aid, Relief, and Economic Security Act (the CARES … Continue reading PPP Loans Create Divergent Disclosure Paths for Brokers and Advisers
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 should not be considered a mere “disclosure agency,” in that she noted that the SEC would use all of the tools at the SEC’s disposal … Continue reading Upshot of SEC’s 2016 Goals – Active Year for Regulatory Rulemaking
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 companies on mergers and acquisitions, advise issuers on raising debt and equity capital in private placements with institutional investors, or provide advisory services on a … Continue reading FINRA Proposes New Registration Category for Corporate Financing Brokers
The MSRB’s current fee for initial registration under Rule A-12 is $100, an amount that has not been changed since its inception in 1975. During its fee review, the MSRB Board concluded that an increase in the initial registration fee from $100 to $1,000 was reasonable to help defray a significant portion of the administrative and operational costs associated with processing an initial registration.
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 business misconduct at Global Arena Capital Corp. As a result, it has barred seven former registered representatives from the securities industry, suspended an eighth person … Continue reading FINRA Cracksdown on Broker Migration
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, the SEC said that in an analysis of 26,600 transactions totaling $1.25 billion of structured securities products, the SEC observed in a significant number of … Continue reading SEC to Broker-Dealers: Better Supervise Sales of Risky Products
The firm should complete the review of the outside brokerage accounts of all associated persons for the prior month.
WASHINGTON — The Securities and Exchange Commission and the Financial Industry Regulatory Authority (FINRA) today announced the opening of registration for their 2015 National Compliance Outreach Program for Broker-Dealers. The program is intended to provide an open forum for regulators and industry professionals to discuss compliance practices and exchange ideas on effective compliance structures. The … Continue reading SEC and FINRA to Hold National Compliance Outreach Program for Broker-Dealers
2014 Renewal Calendar On November 11, 2013, FINRA posted the online Preliminary Renewal Statements on Web CRD and Web IARD, which commenced the 2014 renewal season for broker-dealers and investment advisers. The FINRA renewal calendar is as follows: November 11, 2013 Preliminary Renewal Statements available on Web CRD/IARD. December 13, 2013 Full payment of Preliminary … Continue reading Broker-Dealer & Investment Adviser Renewal Update for 2014
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 Investment Adviser, Private funds and Hedge Funds – Books and Records Understanding the nuts & bolts of Advisers Act Rule 204-2, including retention Reconciling the different … Continue reading 2013 NSCP Southern Regional Meeting – Atlanta
The SEC has recently issued a No-Action Letter that extends the ability for a broker-dealer to treat an investment adviser as if it were subject to an Anti-Money Laundering Program (AML Program) and rely on the investment adviser to perform some or all of its customer identification program (CIP) obligations under rule 31 CFR 103.122. However, … Continue reading SEC Extends Broker-Dealer Reliance on CIPs of Investment Advisers
As the financial services industry has evolved, the supervision of registered persons that are dually registered or affiliated, either with another broker-dealer, an investment adviser or other financial services firm has become increasingly complex. While FINRA speaks regularly about how there is no “one size fits all” approach to compliance, it is clear that supervisory issues … Continue reading White Paper – Dual Registration and FINRA Supervision