We were recently reminded of how difficult it is to re-register for a position in the securities industry after being barred.  See https://www.sec.gov/litigation/admin/2021/ia-5682.pdf.

On February 9, 2021, the United States
Continue Reading Leaving is the Hardest Part Especially if You Want to Re-Enter the Securities Industry

In what has become a yearly occurrence, FINRA has notified its member firms about its intent regarding the member firms’ compliance programs.  See https://www.finra.org/rules-guidance/guidance/reports/2021-finras-examination-and-risk-monitoring-program.

This year, FINRA combined its Report
Continue Reading FINRA’s New Guidance Report… the Name Did Not Change To Protect the Innocent

Recently, the Office of Compliance Inspections and Examinations (“OCIE”) released an alert to broker-dealers and registered investment advisers regarding the risks associated with credential stuffing.  See https://www.sec.gov/files/Risk%20Alert%20-%20Credential%20Compromise.pdf.

Credential stuffing is
Continue Reading The Dark Side Strikes Again: No, Not the SEC, Hackers and Credential Stuffing

The United States Securities and Exchange Commission (“SEC”) adopted amendments to the definitions of both accredited investor under Securities Act of 1933 (“Securities Act”) Regulation D Rule 501 and qualified
Continue Reading SEC Changes Accredited Investor and Qualified Institutional Buyer Definitions

FINRA’s National Adjudicatory Counsel (“NAC”), recently, affirmed a disciplinary panel decision significantly sanctioning a broker-dealer for paying unregistered persons and entities.  See https://www.finra.org/sites/default/files/2020-07/NAC_2014042606902_Silver-Leaf_062920.pdf.

FINRA alleged, among other things, that a
Continue Reading TRANSACTION-BASED COMPENSATION REQUIRES REGISTRATION . . . PERIOD