There are lots of FINRA rules, so many that some don’t get the attention they deserve because others, like the suitability rule or the supervision rule, generally hog the limelight. Moreover, some rules have such narrow application that you may not realize they even exist because they impact only a very few people or entities.
Wolper
How Do You Make a Million Dollars? Become Part of FINRA Senior Management!
I’m not sure that I’m as excited as Navin Johnson was when the new phone books were delivered — https://www.youtube.com/watch?v=-7aIf1YnbbU – but I was pretty happy when FINRA published its 2014 Year in Review and Financial Report. That’s because, at a minimum, I get to enjoy the part where it reveals the compensation paid…
FINRA’s (Mostly) New Background Check Rule Goes Into Effect July 1
As everyone who studies FINRA’s Regulatory Notices is already well aware, two days from now, FINRA’s rule requiring background checks on prospective registered representatives goes into effect. A lot of what the new rule mandates is not new, but, as there are some things that clearly were not required before, it is worth taking a…
David Slays Goliath…And Goliath Is Pissed
I reported a few weeks ago on the victory that my clients, Mark Robare and Jack Jones, achieved in the administrative proceeding that the SEC initiated against them last year. Against all odds, they convinced Judge Grimes that not only had they not committed the fraud claimed by the SEC, but, in Judge Grimes’ words,…
FINRA’s Code Of Procedure: Unfair To The Gander
We have complained before in this blog about some of the obvious inequities associated with the FINRA Enforcement process that disfavor respondents. But I heard of a new one this week from a colleague, so I thought I would take the opportunity to revisit the issue.
While there are several things problematic about the Code…
BrokerCheck: Please, Sir, May I Have Some More?
FINRA recently announced a multi-million dollar ad campaign to increase public awareness of BrokerCheck, in an effort to increase the number of investors who actually use it. I had a few initial thoughts.
First, as I have observed before, it is hardly a secret that BrokerCheck does not serve as the basis for the vast…
David Slays Goliath: Texas Investment Advisor Beats SEC In Administrative Proceeding
If you have been a regular reader of this Blog, or even if you just browse the Wall Street Journal on occasion, you have undoubtedly noticed the attention being given over the last few weeks to the SEC’s decision increasingly to bring its Enforcement cases before Administrative Law Judges, rather than in federal court.…
Day Two of FINRA’s Annual Conference
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…
Day One of FINRA’s Annual Conference
Here are my thoughts after Day One.
At a minimum, you would have to admit that FINRA has a sense of humor: the song they played when Rick Ketchum, FINRA’s Chairman, was introduced to give his keynote speech was “Why Can’t We Be Friends,” the 1975 song by War. Predictably, there were few laughs after…
Notes From The Annual FINRA Conference
I am in DC, to attend the annual FINRA conference that starts tomorrow morning. I have been to many of these over the years, formerly as the Director of NASD’s Atlanta District Office, but, over the last ten years, as a lawyer who defends brokers and broker-dealers against, among other things, FINRA allegations of misconduct.…