By now you have probably read FINRA’s recent “Targeted Exam Letter” entitled “Establishing, Communicating and Implementing Cultural Values.”  In case you haven’t, it is clear that FINRA is following up on the promise it made in January in the 2016 Regulatory & Examination Priorities Letter to “formalize [its] assessment of firm culture while

I posted several blogs this summer about our victory over the SEC in the Robare case (which, naturally, has been appealed by the SEC’s unhappy Division of Enforcement). One of the key elements in our ability to prevail in that matter was my client’s extensive use of outside securities consultants to assist in the preparation

Much like some people (well, me, anyway) enjoy debating what was the first “punk rock” song to go mainstream (Pump It Up, by Elvis Costello, of course), others more erudite than I prefer, instead, to argue about what it was that initially propelled FINRA down its current Enforcement oriented path. To me, the answer has