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
Broker-Dealer Registration
Who Wants To Know How OBA Disclosures Can Save Your Firm?
By Joshua Horn on
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…
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Who still thinks FINRA is not interested in elder investor issues
By Joshua Horn on
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…
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So what does the expedited release of a Form U-5 mean for you
By Joshua Horn on
As of December 12, 2015, FINRA will release Form U-5s within three business days of a member firm’s submission, instead of the fifteen days currently provided for under Rule 8312.
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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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FINRA’s New EB-5 Disclosure Requirements re: Foreign Finders
By Fox Rothschild LLP on
New FINRA Rule 2040 became effective late last month, requiring broker-dealers who sell EB-5 securities disclose to investors the amount of finder fee payments to non-registered foreign persons and receive…
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Who Needs The SEC Anyway
By Joshua Horn on
At least one New York City official would answer that question in the negative. The city comptroller released a proposal that would require a financial advisor to clearly state whether…
Why You Need To Think Twice About That New Hire
By Joshua Horn on
Starting July 1, member firms are required to have written procedures to verify the accuracy and completeness of the information in a registered representative’s U-4 within 30 days of the…
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M&A BROKER RELIEF FROM REGISTRATION
By Fox Rothschild on
The SEC’s Division of Trading and Markets stated that it would not recommend enforcement action if a “mergers and acquisitions broker” were to engage in the sale or purchase of…
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When in Rome Do as the Romans or At Least Play by the Rules
By Fox Rothschild on
Usually, we spend a fair amount of time advising our American broker-dealer clients, who do business overseas, that they have to follow the rules of those countries as well. However,…
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