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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Conflicts of Interest
So who really thinks the SEC is not focused on elder investors
By Joshua Horn on
If there is any question that the SEC is focused on elder investor issues, look no further than its recent program announcement. The SEC initiated a program designed to examine…
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What The Heck Is A Senior Designation
By Joshua Horn on
That is one of the questions FINRA sought to answer in its recent National Seminar Investor Initiative. FINRA confirmed that many representatives use such designations, but some of them are…
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The DOL Proposes A Fiduciary Duty Rule; Is This The Beginning Of The End
By Joshua Horn on
The Department of Labor delivered on a longstanding but controversial promise when it recently proposed a fiduciary duty rule for all brokers who work with retirement accounts. The primary purpose…
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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…
Josh Horn’s Great Guidance on RIA Conflicts of Interest
By Fox Rothschild on
We are pleased to share with everyone Josh Horn’s excellent guidance on RIA conflicts of interest, recently, published in the Practical Compliance and Risk Management for the Securities Industry,…
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What Are You Doing About The New Supervision Rules
By Joshua Horn on
FINRA noted in its exam priorities that it will be focusing on firms’ compliance with the new supervision rules (FINRA Rules 3110, 3120, 3150 and 3170). These rules became effective…
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Who Wants To Speak With Me, Oh No
By Joshua Horn on
Anyone in a service industry has had that dreaded feeling. You see your email or caller identification and realize it is “that” client trying to reach you. The client I…
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My Client Has Dementia, Now What
By Joshua Horn on
What do you do when your elderly client begins to make bizarre withdrawals? Is there something wrong when your elderly client starts transferring funds to finance a Nigerian soccer teams? …
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Look Before You Tweet
By Joshua Horn on
FINRA recently sanction a registered representative for tweets made some time ago. The offending tweets referenced a stock that he did not disclose that he owned and were otherwise biased …
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