Last week I posted a blog about the dangers of not heeding findings made during a regulatory exam, at least findings of clear, undisputable compliance issues that cannot be meaningfully defended. Today I am writing to highlight a corollary rule: if one customer points out the existence of a real problem, again, a clear problem

There is no question in my mind that the quality of FINRA examiners is a bit uneven.  Some are smart and insightful and helpful; others are, well, not.  Most of the time, they do know what they’re talking about.  That means the opportunity to make legitimate arguments against exam findings can, at least sometimes, be

As I have discussed before, there are some rule violations that are going to happen no matter what FINRA says about them, no matter how many Enforcement cases it brings, and no matter what BDs do to “detect and prevent” such violations. A prime example of such is outside business activities, or OBAs.  The rule

As promised, FINRA has released its first Report outlining common findings from its examinations, in an effort to help member firms comply with the rules and, presumably, avoid problems that other firms encountered.  A noble idea, especially for an entity not exactly known (at least lately) for its proactive measures to assist BDs with their

A client of mine bought a BD, thereby requiring him to go through the CMA process. It was a very small firm, with fewer than ten registered reps.  He was a newly minted 24, so he had other, more experienced principals on board to handle all supervisory responsibilities.  His job, as outlined in the firm’s