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
In December 2020, the New York State Attorney General altered its filing rules to align with those required by the SEC’s requirements for a Regulation D Rule 506 offering. Now,
Continue Reading New Reg D Rule 506 Filing Rules for New York
Our partner, Patrick Egan, authored an excellent opinion for the Philadelphia Inquirer on the death penalty and moratoriums. See https://www.inquirer.com/opinion/commentary/death-penalty-moratorium-pennsylvania-governor-wolf-capital-punishment-20210201.html.
Continue Reading Patrick Egan Authors Insightful Piece on Death Penalty Moratoriums
![-incompetence-14220[1]](https://securitiescompliancesentinel.foxrothschild.com/wp-content/uploads/sites/123/2020/04/incompetence-142201.jpg)
In a stark 3-2 vote along political lines, the SEC announced today that it was proposing new rules relating to finders. Essentially, if the proposed rules are, ultimately, approved, the
Continue Reading SEC Moves in a Very Different Direction on Finders
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
Money service businesses received a reprieve last week that will make cryptocurrency firms very happy since they will be able to more easily expand across the United States. The Conference
Continue Reading Uniform Money Transmitting Rules May Make It Easier for the Cryptocurrency Business
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
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) conducted a series of examinations into private fund advisers. See the SEC risk alert here. To say the least, OCIE
Continue Reading SEC Prepping for a New Round of Attacks on Fund Advisers