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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
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
Although we are certain that Shakespeare never had to deal with the vagaries of Regulation BI, we do, and, in a series of questions relating to Regulation BI, the SEC
Continue Reading “A Rose by Any Other Name Would Smell as Sweet,” Not So for BDs and Advisors
Recently, a REIT sought to avoid using a broker-dealer in a distribution. Woe, onto those who seek to avoid the broker-dealer, especially when it leads to a SEC investigation and
Continue Reading YOU SHOULD ALWAYS USE YOUR FRIENDLY NEIGHBORHOOD BROKER-DEALER!
Most brokers despise the fact that they need to re-take their examinations if they are not employed with a broker-dealer for 2 years or if they are not associated with
Continue Reading Let’s Not Get Too Excited with FINRA’s Proposal on Re-Taking Exams
At Fox Rothschild, we are constantly advising clients regarding the peril of engaging in the securities industry without the proper license. In fact, we have developed materials to provide our
Continue Reading If You Want Trouble, Do Not Register as a Broker-Dealer
The SEC recently announced that an equity advisory firm and its owner agreed to pay more than $3.1 million to resolve charges that they improperly engaged in brokerage activity, as
Continue Reading To be a broker-dealer or not to be; that is the SEC’s question
Over the years that I have defended broker-dealers and investment advisors, a more robust overview of outside business activity (OBA) disclosures would have gone a long way to disprove a
Continue Reading Who Wants To Know How OBA Disclosures Can Save Your Firm?
As you may know, FINRA, last April, launched a senior helpline to address issues pertaining to senior investors. According to recent reports, FINRA received calls on many different issues such
Continue Reading Who still thinks FINRA is not interested in elder investor issues
