Like it has in the past, FINRA is sharply focused on examining brokers with a disciplinary past, including the identification and examination of such brokers being placed at the top
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FINRA Compliance
What are you doing to prevent a data breach
By Joshua Horn on
A broker-dealer recently agreed to pay a $650,000 fine after an OSJ’s cloud vendor failed to adequately protect customer information. Apparently, an outside hacker was able to gain access to…
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So Who Wants Senior Clients
By Joshua Horn on
In its never-ending effort to thwart senior investor fraud, FINRA recently proposed a new rule to the SEC. This proposal would require member firms to obtain the name of a…
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When just saying “no” is a good thing
By Joshua Horn on
In the hectic world of financial services, registered representatives and investment adviser representatives are always looking to increase their assets under management. At what cost? Are there situations where you…
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Don’t Argue; The Client Is Always Right Even When They Are Not
By Joshua Horn on
Over the years that I have defended broker-dealers and investment advisors on customer-initiated claims, I have seen many things that would make any compliance officer cringe. One spine tingling (not…
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The SEC Now Has A Lead Cybersecurity Senior Adviser: Now What?
By Joshua Horn on
The SEC recently created a new position associated with cybersecurity; senior adviser to the chair for cybersecurity (Christopher R. Hetner). Mr. Hetner has an extensive background in information technology and,…
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Elder Abuse Takes Another Twist and Turn
By Joshua Horn on
If you thought the SEC and FINRA were serious about elder issues, welcome to the Alabama, Indiana and Vermont. Each has focused on elder abuse issues.
These states will have…
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So What’s Your Firm’s Culture?
By Joshua Horn on
If you cannot answer this question, you may have an issue when you have your next FINRA exam. After all, firm culture is a FINRA exam priority. Does your firm…
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What to do about a stupid client
By Joshua Horn on
Anyone in a professional service business, like being a stock broker, have been faced with a client who decides to make a stupid decision. But the issue we all face…
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Why a Bad Broker Is Not Like Fine Wine
By Joshua Horn on
Unfortunately, a bad broker does not take on the same attributes as a fine wine. Bad brokers do rarely improve with time.
At least this was the recent message of…
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