By Michael Gross on Posted in Compliance,FINRA,Rule 2165,Senior InvestorsA few weeks ago, I posted a blog about FINRA’s new rule concerning senior investors. My take was largely that the rule made sense, but only to the extent that it provides protections for BDs that encounter the need to share otherwise confidential information about a customer due to concerns about the customer’s health, particularly… Continue Reading
By Alan Wolper on Posted in FINRA,Rule 2165,Rule 4512,Senior Investors,UncategorizedWe have written before about senior investors, but I saw a couple of things in the last couple of weeks that suggests this subject needs to be revisited. First, back in February, the SEC got around to passing FINRA’s proposed rules to protect senior investors, including both new Rule 2165 and amendments to existing Rule… Continue Reading
By Alan Wolper on Posted in Compliance,Culture,FINRA,Senior InvestorsIn the blog I posted yesterday, I discussed a late Xmas present that the 10th Circuit gave everyone who is subject to the SEC’s jurisdiction. Today, let’s talk about FINRA’s New Year’s gift to its member firms: the annual Regulatory and Examination Priorities Letter, which was released this week. As is typically the case with… Continue Reading
By Alan Wolper on Posted in AML,CCO,CCO liability,Compliance,Culture,FINRA,Senior Investors,SIFMAThe Rick Ketchum Show. Today’s sessions opened with what was likely the highlight of the entire conference, Rick Ketchum’s swan song “conversation” with Ira Hammerman, GC of SIFMA, before he toddles off into retirement. Granted, these interviews never remotely approach Sixty Minutes intensity, but this year’s featured even more coddling than ever: What would you… Continue Reading
By Heidi VonderHeide on Posted in Compliance,Expungement,FINRA,Senior Investors,Suitability,SupervisionYesterday, FINRA released its annual Examination Priorities Letter in which it set forth the top issues that would guide its examinations in the coming year. Running 13 pages in length (while complaining about having to be so “brief”), FINRA set forth some of the “many areas of potential concern” it expects to encounter this year.… Continue Reading
By Nathan Lamb on Posted in Arbitration,FINRA,Rule 1250,Senior InvestorsIn a recent blog post, I wrote about the challenge a rapidly deteriorating change in mental capacity can cause BDs and RRs alike. Often, we are asked to speak to groups and firms, and this subject is a popular one. In my view, there are a couple of reasons for this development. First, FINRA has… Continue Reading
