Broker- Dealer Law Corner

Broker- Dealer Law Corner

Category Archives: Senior Investors

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The Nuts And Bolts Of FINRA’s New Financial Exploitation Rule

Posted in Compliance, FINRA, Rule 2165, Senior Investors
A few weeks ago, I posted a blog about FINRA’s new rule concerning senior investors.  My take was largely that the rule made sense, but only to the extent that it provides protections for BDs that encounter the need to share otherwise confidential information about a customer due to concerns about the customer’s health, particularly… Continue Reading

FINRA’s New Rules On Seniors: Let’s Protect Them From Their Own Bad Decisions?

Posted in FINRA, Rule 2165, Rule 4512, Senior Investors, Uncategorized
We have written before about senior investors, but I saw a couple of things in the last couple of weeks that suggests this subject needs to be revisited. First, back in February, the SEC got around to passing FINRA’s proposed rules to protect senior investors, including both new Rule 2165 and amendments to existing Rule… Continue Reading

FINRA Releases Its 2017 Exam Priorities: No More “Culture Of Compliance” References, Plus The List Of Usual Suspects

Posted in Compliance, Culture, FINRA, Senior Investors
In the blog I posted yesterday, I discussed a late Xmas present that the 10th Circuit gave everyone who is subject to the SEC’s jurisdiction.  Today, let’s talk about FINRA’s New Year’s gift to its member firms: the annual Regulatory and Examination Priorities Letter, which was released this week.  As is typically the case with… Continue Reading

Highlights from Day Two of SIFMA-CL Conference

Posted in AML, CCO, CCO liability, Compliance, Culture, FINRA, Senior Investors, SIFMA
The Rick Ketchum Show. Today’s sessions opened with what was likely the highlight of the entire conference, Rick Ketchum’s swan song “conversation” with Ira Hammerman, GC of SIFMA, before he toddles off into retirement. Granted, these interviews never remotely approach Sixty Minutes intensity, but this year’s featured even more coddling than ever: What would you… Continue Reading

FINRA’s 2016 Examination Priorities Letter: Focus On “Firm Culture”

Posted in Compliance, Expungement, FINRA, Senior Investors, Suitability, Supervision
Yesterday, FINRA released its annual Examination Priorities Letter in which it set forth the top issues that would guide its examinations in the coming year. Running 13 pages in length (while complaining about having to be so “brief”), FINRA set forth some of the “many areas of potential concern” it expects to encounter this year.… Continue Reading

Day Two of FINRA’s Annual Conference

Posted in Enforcement, Examination, FINRA, Registered Representative, Rule 2111, Senior Investors, Suitability, Supervision
I wish I was able to report some fireworks, or something semi-controversial, but FINRA and its hand-picked panelists managed to avoid saying anything particularly remarkable in any way. If you have never attended one of these conferences, and think that people come to learn cutting edge strategies, forget it. It is all very basic, very… Continue Reading
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