Thanks to Chris for not only making the personal sacrifice of traveling from frigid Chicago to sunny Florida to attend the SIFMA Compliance and Legal conference last week, but for providing these helpful comments about the sessions he attended. – Alan
I attended the four-day SIFMA Compliance and Legal seminar last week, and there…
Thanks to Heidi for today’s post. – Alan
Today, the SEC put out its 2021 Exam Priorities, available here. It is about 40 pages long and covers a lot of topics. While I encourage everyone to read through the document, here are the primary focus items for 2021:
Overarching Themes / Focal Points:
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After having proudly served for decades, and surviving a dramatic face-lift in 2012 (when old NASD Rule 2310 was replaced by shiny new FINRA Rule 2111), it seems that the “suitability rule,” as we’ve come to know it, has, at long last, been quietly sent out to pasture by FINRA. Although the title of Reg…
I have blogged before about hold recommendations. Surprisingly – at least to me – the statistics I get from the publisher of this blog reveal that more people have read that particular post than anything else I have written since I started this thing a few years ago. That has to mean something, right? …
Heidi is my go-to destination for all things Reg BI. Here’s a quick, but really helpful, update from her. – Alan
This week OCIE issued twin alerts relating to the upcoming implementation of Reg BI. A lot of the statements are nothing new – brief repetitions of the Regulation, the four obligations, etc. None…
My partner, Heidi VonderHeide, has busied herself these last few months learning everything she can about Reg BI. Happily, here is her post on the subject, and it doesn’t predict gloom and doom in the new year as that regulation is implemented. – Alan
Just before the Holidays, I attended FINRA’s one-day Reg BI seminar…
Between the usual holiday season madness and a recent trial, I have been a little tied up lately. Happily, Chris Seps has stepped up with this excellent piece on Reg BI. – Alan
My young boys will sometimes chase me around the house, catch me, and yell “gotcha” as they drag me off to…
This post is about Reg BI, but if you really want to learn about it, as opposed simply to listening to me gripe, I urge you to register for the webcast that my partners Heidi VonderHeide and Rob Betman will present on Wednesday, December 11, 2019, at 2:00 PM EST. It is just one of…
Selflessly, Blaine Doyle recently attended a presentation here in Chicago by the SEC and CFTC, so you didn’t have to do it yourself. Here is his recount of the highlights. – Alan
Anyone who has sat through a talk by financial regulators is undoubtedly familiar with the refrain from the individuals that they do not speak for the Commission and that the opinions offered are their own. Even with that disclosure (and they ALWAYS make that disclosure), regulators are still notoriously tight lipped when it comes to just about anything, but especially if it relates to Enforcement. However, when two high ranking officials from the CFTC and SEC decided to present, as the star attractions, at the Chicago Bar Association, they had no choice but to spill the beans. While nobody would accuse them of having given up state secrets, they did offer some insights into where their respective Commissions are and, more importantly, where they are going. With that in mind, here is what they had to say (with special emphasis on the securities side):
While the government shutdown of early 2019 is ancient history to most of us, the speakers from both the CFTC and SEC emphasized the disruption that the break caused to their respective organizations and personnel. Moreover, on the issue of government funding, they both noted that their organizations are understaffed from past hiring freezes and are trying to backfill positions that have been open for some time. The speaker from the CFTC mentioned that in some respects his organization had been in “triage” mode due to personnel shortages and that he was hoping that the additional hires will help ease the work load. So why does this matter to the reader? If you work in the industry, it would be reasonable to expect that as both organizations hire additional staff, scrutiny on registrants and, possibly, the number of enforcement actions will increase in the coming years.
Continue Reading “The Opinions Offered Today Are Mine Alone And Do Not Represent The Commission” — A Summary Of Recent Remarks From SEC And CFTC Officials
