Broker- Dealer Law Corner

Broker- Dealer Law Corner

Category Archives: Private Placement

Subscribe to Private Placement RSS Feed

(Another) Landslide Victory: FINRA Enforcement Offers ZERO Evidence Of Fraud

Posted in Disciplinary Process, Enforcement, FINRA, Private Placement, Sanctions
At the end of last week, we received our second[1] decisive win in a FINRA Enforcement case in a matter of days. Following a two-day hearing back in July, the hearing Panel dismissed all charges against our clients Paul J. McIntyre and MSC-BD, LLC. While any victory is nice, and doing justice for a client… Continue Reading

The Ongoing Puzzle Of Ongoing Due Diligence

Posted in Disciplinary Process, Due diligence, Enforcement, Examination, Fiduciary Standard, FINRA, Private Placement, Reg D, Rule 2111, Supervision
I am currently in the midst of a FINRA examination that is largely focused on the adequacy of the due diligence that my broker-dealer client conducted of a private placement. What is puzzling about the exam is that FINRA is not just interested in the due diligence that was conducted prior to effecting any sales… Continue Reading
.