Broker- Dealer Law Corner

Broker- Dealer Law Corner

Category Archives: Outside business activities

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BD Learns It’s Not Enough To Have A Supervisory Procedure For OBAs, You Actually Have To Follow It

Posted in Enforcement, FINRA, Outside business activities, Rule 3270, Uncategorized
In most Enforcement cases involving outside business activities, it is the registered rep who is named as the respondent, and the allegation is that the RR failed to provide notice (or timely notice) to his or her broker-dealer about the OBA. On occasion, however, it is the BD that gets tripped up, typically for not… Continue Reading

FINRA’S 2018 Exam Priorities Reflect Business As Usual

Posted in Annual Report, Cybersecurity, Disclosure, FINRA, Outside business activities
I would imagine that the point of FINRA releasing its list of exam priorities each year is to help firms who are actually going to be examined, by providing a glimpse into FINRA’s playbook so they can address, proactively, the issues they know FINRA will focus on. To be forewarned is to be forearmed, right? … Continue Reading

Can FINRA Deliver On A Promise To Provide Meaningful Relief To Compliance Departments?

Posted in Compliance, FINRA, Outside business activities, Rule 3270
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… Continue Reading

FINRA Provides The Blueprint For Monitoring Outside Business Activities

Posted in Disciplinary Process, Disclosure, Enforcement, FINRA, Outside business activities
Outside business activities are in the news. In Reg Notice 17-20, FINRA announced that it was seeking comments in an effort to learn whether or not the existing rules governing OBAs are effective.  (The comment period is open until late June, so if you have strong feelings on the subject, now is the time to… Continue Reading
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