Broker- Dealer Law Corner

Broker- Dealer Law Corner

Category Archives: Rule 2111

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The Ongoing Puzzle Of Ongoing Due Diligence

Posted in Disciplinary Process, Due diligence, Enforcement, Examination, Fiduciary Standard, FINRA, Private Placement, Reg D, Rule 2111, Supervision
I am currently in the midst of a FINRA examination that is largely focused on the adequacy of the due diligence that my broker-dealer client conducted of a private placement. What is puzzling about the exam is that FINRA is not just interested in the due diligence that was conducted prior to effecting any sales… Continue Reading

Day Two of FINRA’s Annual Conference

Posted in Enforcement, Examination, FINRA, Registered Representative, Rule 2111, Senior Investors, Suitability, Supervision
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… Continue Reading

Why are Senior Investors so Special? (Part 1)

Posted in Enforcement, FINRA, Rule 2111, SEC, Suitability
Over the last few months and years, securities regulators have repeatedly emphasized the special care and attention senior investors[1] should be afforded by broker-dealers and their associated persons. As part of that focus, on April 15, 2015, FINRA and the SEC Staff published their National Senior Investor Initiative Report. The report highlighted recent industry trends… Continue Reading