Yesterday, the SEC held its 2015 “National Compliance Outreach Program for Broker-Dealers.” The program was designed to “provide[] an open forum for regulators and industry professionals to share strong compliance practices and promote the exchange of ideas to develop an effective compliance structure.” In the spirit of this cooperation, SEC Chairwoman White opened the conference
UB Greensfelder
For Those About to be Suspended: The Guessing Game is Over Whether You Can Receive Your Trails
By UB Greensfelder on
Posted in Disciplinary Process, Enforcement, FINRA, Rule 2040, Rule 8311, Sanctions, Supervision, suspension, Trail commissions
There are lots of FINRA rules, so many that some don’t get the attention they deserve because others, like the suitability rule or the supervision rule, generally hog the limelight. Moreover, some rules have such narrow application that you may not realize they even exist because they impact only a very few people or entities.…
How Do You Make a Million Dollars? Become Part of FINRA Senior Management!
By UB Greensfelder on
I’m not sure that I’m as excited as Navin Johnson was when the new phone books were delivered — https://www.youtube.com/watch?v=-7aIf1YnbbU – but I was pretty happy when FINRA published its 2014 Year in Review and Financial Report. That’s because, at a minimum, I get to enjoy the part where it reveals the compensation paid…
FINRA’s (Mostly) New Background Check Rule Goes Into Effect July 1
By UB Greensfelder on
As everyone who studies FINRA’s Regulatory Notices is already well aware, two days from now, FINRA’s rule requiring background checks on prospective registered representatives goes into effect. A lot of what the new rule mandates is not new, but, as there are some things that clearly were not required before, it is worth taking a…
David Slays Goliath…And Goliath Is Pissed
By UB Greensfelder on
I reported a few weeks ago on the victory that my clients, Mark Robare and Jack Jones, achieved in the administrative proceeding that the SEC initiated against them last year. Against all odds, they convinced Judge Grimes that not only had they not committed the fraud claimed by the SEC, but, in Judge Grimes’ words,…
FINRA Got It Right – The New Definition of a Non-Public Arbitrator
By UB Greensfelder on
Posted in Arbitration, FINRA
By now, it should be clear, we are oft to criticize FINRA in this blog. Much of that criticism is self-inflicted by, in our view, their unfair or unreasonable decisions. But, in a departure from the norm, I want to recognize an instance when FINRA is getting something right.
Effective this Friday, there will be…
FINRA’s Code Of Procedure: Unfair To The Gander
By UB Greensfelder on
We have complained before in this blog about some of the obvious inequities associated with the FINRA Enforcement process that disfavor respondents. But I heard of a new one this week from a colleague, so I thought I would take the opportunity to revisit the issue.
While there are several things problematic about the Code…
BrokerCheck: Please, Sir, May I Have Some More?
By UB Greensfelder on
FINRA recently announced a multi-million dollar ad campaign to increase public awareness of BrokerCheck, in an effort to increase the number of investors who actually use it. I had a few initial thoughts.
First, as I have observed before, it is hardly a secret that BrokerCheck does not serve as the basis for the vast…
David Slays Goliath: Texas Investment Advisor Beats SEC In Administrative Proceeding
By UB Greensfelder on
If you have been a regular reader of this Blog, or even if you just browse the Wall Street Journal on occasion, you have undoubtedly noticed the attention being given over the last few weeks to the SEC’s decision increasingly to bring its Enforcement cases before Administrative Law Judges, rather than in federal court.…
Day Two of FINRA’s Annual Conference
By UB Greensfelder on
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…