One certainty in the brokerage world is that registered representatives often switch from one member firm to another. There is nothing wrong with the switch, but there is a
FINRA Enforcement
FINRA Is Sanctioning What
By Joshua Horn on
In Notice to Members 17-13, FINRA announced changes to its sanction guidelines. In other words, FINRA has listed its new top hits that it is pursuing. Two items bear…
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FINRA, A/K/A the Fine Machine
By Joshua Horn on
According to a recent report of the Eversheds Sutherland firm, 2016 was a banner year for FINRA-assessed fines. FINRA collected a record $176 million in 2016. So what gives?
The…
One Man’s Rogue Broker Is Another Man’s Treasure
By Joshua Horn on
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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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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A Data Breach! You Better Check The Law Of The States In Which You Have Customers
By Joshua Horn on
Consistent with the ongoing guidance/requirements from the SEC and FINRA, all firms must have and enforce data security policies and procedures. Even the best policies and procedures may, however, 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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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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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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Take Away From The NSCP New York Regional Conference
By Joshua Horn on
It was great speaking at the May 17 New York NSCP regional conference on risk issues facing firms where Ernie Badway and I discussed cyber-security, risk issues, regulatory matters, issues…
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