I am fond of saying that, at least generally speaking, the most important document in a customer arbitration alleging unsuitable recommendations is the new account form. If the NAF is in good shape, i.e., it is accurate, it is complete, it is up-to-date, it doesn’t have any changes or white-outs, then I am free to
Books and records
The Very Pricey Real Estate At The Intersection Of The Old Books-And-Records Rule And The New Reality Of How People Communicate
By Alan Wolper on
Posted in 17a-4, Books and records, SEC
Happy New Year! I hope you had an enjoyable holiday season. At least happier than that of JP Morgan Securities, which, right before Christmas, got to write checks to the SEC and the CFTC totaling $200 million. That’s a lot, even for JPMS. How did this happen?
Well, the story starts with a very old,…