In a recent risk alert, the SEC announced that it was instituting a second exam priority focused on cybersecurity at broker-dealers and registered investment advisors. The SEC decided to conduct
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Books and Records
What an amended FINRA Rule 8312 may mean to you.
By Joshua Horn on
FINRA has released for comment its proposed amendment to Rule 8312, otherwise known as the BrokerCheck Disclosure rule. As it currently stands, FINRA waits for 15 days before it releases…
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Why therapeutic neglect and an 8210 request do not go hand in hand
By Joshua Horn on
In first of a series of articles on FINRA enforcement and the disciplinary process, Scott Matasar gave some sage advice on dealing with an 8210 request. The biggest take away…
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What do you need to know about the latest FINRA sweep exam
By Joshua Horn on
FINRA recently sent out targeted exam letters focused compensation practices. The intent of this targeted exam is to assess how firms identify, mitigate and manage conflicts of interest when it…
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Who wants some advice regarding cyber-threats?
By Joshua Horn on
A recent article in Onwallstreet.com highlighted certain areas of focus for investment advisors/broker-dealers when it comes to addressing cyber-threats. The article focused on four areas of particular significance.
First,…
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Who wants to know some pre and post data breach considerations
By Joshua Horn on
In a recent blog by Chris Pogue (a digital forensic expert), he highlighted a handful of considerations for firms both pre and post data breach. After all, the issue is…
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Who wants more cyber-security guidance
By Joshua Horn on
In a recent article written by Bill Winterberg in the Journal of Financial Planning he highlighted a number of pitfalls that advisors commonly fall into that expose sensitive client data…
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Do you really need a reason why not to provide your client with a personal email address
By Joshua Horn on
Not too long ago, I tried a case that had, among other issues, the improper use of the advisor’s personal email account. That improper use serves as a valuable lesson…
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The Film Don’t Lie When You Are Defending Yourself
By Joshua Horn on
When you are faced with a customer complaint, the single most important thing in my expense is the content of the file. If it is not there, it will not…
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What Does The “E” In Email Mean Redux
By Joshua Horn on
I recently blogged about the meaning of the “E” in email. For a further discussion of the dangers associated with email, you can listen to this podcast. The…
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