I heartily endorse this post from my colleague, Chris, who’s been quiet of late. It says a lot about FINRA, in terms of how it deigns to spend your assessment money, how fairness in the Enforcement process can be completely illusory, and how it is consistently unable to convince much of the investing public that
broker-dealers
FINRA Proposes To Dispense With Due Process, All Because It’s Failed To Do Its Job Of Policing The Markets
By UB Greensfelder on
Reading Reg Notice 19-17 makes me think of the legal arguments that I’ve recently read regarding whether a president can be found guilty of obstructing justice if the actions in question were taken out in the open, for everyone to see. Here, FINRA’s proposed power grab is simply outrageous, but, you got to give them…
FINRA’s Proposal On High-Risk Firms Is A Must-Read, But Hardly A Must-Enjoy
By UB Greensfelder on
Posted in FINRA, High-Risk firms
I apologize for all the posts this week, but I am traveling and am in a different time zone, so I am awake at hours when, ordinarily, I would be asleep, giving me time to muse. Anyway, given that, I will not test your willingness to indulge my random thoughts a third time in one…
FINRA AWC Includes Waiver Of A Fine: Is This A Sign Of Good Things To Come?
By UB Greensfelder on
Way back in 2006, NASD issued Notice to Members 06-55, which tweaked the Sanction Guidelines to allow not just the size of the firm to be taken into consideration when determining the appropriate sanctions to be meted out, but, more importantly, how well, or how poorly, the firm is doing on its income statement.…
Is FINRA’s New Regulatory Notice On Departing Reps A Unicorn?
By UB Greensfelder on
FINRA came out with a slightly weird Regulatory Notice last week. In a succinct document, barely over two pages, FINRA addressed something that may, or may not, actually be of concern to anyone. In short, Regulatory Notice 19-10 states FINRA’s position on what a broker-dealer is supposed to tell the customers of a registered representative…
Wedbush Learns That It’s Not Enough Just To Spot Red Flags
By UB Greensfelder on
Posted in SEC, Supervision
I have been busy the last month getting ready for a big arbitration, and attending the first week of what looks like is going to be a four- or five-week slog when all is said and done. So, I am just catching up on some recent developments, and mulling over what might be of interest…
FINRA Says, Proof? We Don’t Need Your Stinkin’ Proof
By UB Greensfelder on
If you are a regular reader of this blog, then you know that over my last few posts, I have been talking about an increasingly visible effort by FINRA to turn its regulatory eye from rogue brokers – who have been an irritant to FINRA and NASD for decades – to rogue firms (my term,…
FINRA Is Going After “High-Risk” Firms, But First Has To Invent The Definition Of High-Risk
By UB Greensfelder on
I told you two weeks ago in my blog post that this would happen. I told you that when Robert Cook announced the topics to be taken up at the February/March FINRA Board meeting in Boca Raton, he slipped and used the new phrase “high-risk firms.” Well, in yesterday’s announcement about what actually took place…
Hope Springs Eternal
By Ken Berg on
My partner, Ken Berg, writes about his recent meeting with the NCLA, a group that anyone who has an administrative practice should be familiar with. – Alan
I had the privilege of being invited to attend in Washington, D.C., on February 28, 2019, the inaugural panel discussion hosted by a relatively new nonprofit civil rights…
FINRA Coins A Scary New Term: “High-Risk Firms”
By UB Greensfelder on
Yesterday, FINRA sent a seemingly innocuous memo to member firms giving a brief outline of the subjects that its Board will take up at its meeting this week in sunny Boca Raton, Florida. (Wait, the Board isn’t meeting in Washington, as it normally does, but, rather, in south Florida? Oh, right, it’s February. Much better…