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
Robert Cook
FINRA’s Exam Guidance Is A Big Yawn
As promised, FINRA has released its first Report outlining common findings from its examinations, in an effort to help member firms comply with the rules and, presumably, avoid problems that other firms encountered. A noble idea, especially for an entity not exactly known (at least lately) for its proactive measures to assist BDs with their…
FINRA In The News, And Not In A Good Way
It has been said that there’s no such thing as bad publicity, but I wonder if FINRA feels that way after having been featured in a number of less-than-favorable, or at least curious, media stories over the last couple of weeks.
First, two weeks ago, Bruce Kelly of Investment News ran a story with this…
What Is FINRA’s Job?
A client of mine bought a BD, thereby requiring him to go through the CMA process. It was a very small firm, with fewer than ten registered reps. He was a newly minted 24, so he had other, more experienced principals on board to handle all supervisory responsibilities. His job, as outlined in the firm’s…
FINRA’s Annual Report: I Wish It Was Fake News
This past week, FINRA very, very quietly released its Annual Report for 2016. Too quietly, as they say in the movies. No press release. No press conference. No media attention at all, hardly. As President Trump just asked about State Election Commissioners who refused to respond to a request from his Election Fraud taskforce for…
Rogue Brokers: The Numbers Do Not Tell The Whole Story
Not too long ago, I blogged a couple of times about the amount of attention that is suddenly being paid to the number of registered representatives with disciplinary histories working for FINRA member firms, i.e., the so-called recidivists (who used to be called “rogue reps”). Among the complaints I voiced was the fact that while…
FINRA’s Board Continues To Bend In the Wind Of Criticisim
On Wednesday, the FINRA Board met and discussed two topics that I recently blogged about: recidivist brokers and unpaid arbitration awards. In predictable fashion, FINRA withered in the face of criticism that its existing rules and policies are somehow not tough enough on its member firms, and embarked on a proposed series of steps…
Is FINRA Guilty Of Gaslighting Us When Its CEO Says Things Will Be Different?
Since the presidential election, heck, since the campaign, my friends and family will readily attest that my new favorite word is “gaslighting.” According to Wikipedia, it is “is a form of manipulation that seeks to sow seeds of doubt in a targeted individual or group, hoping to make the target question their own memory, perception,…
FINRA Releases Its 2017 Exam Priorities: No More “Culture Of Compliance” References, Plus The List Of Usual Suspects
In 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…