Business Insurance reported late last week that the Securities and Exchange Commission will award $5-6 million to a whistleblower who provided information on securities violations that would have been “nearly
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SEC Compliance
Take Away From The NSCP New York Regional Conference
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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Why Face-to-Face Meetings Are Necessary for Proper Supervision
In this day and age of instant information and overstretched supervisory personnel, you have to be careful to avoid forgoing a very useful supervisory tool. Meeting face to face with…
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Why A Free Dinner Is Never Really Free
The SEC recently charged four investment advisors who allegedly used free dinners to entice older clients to their firm. At these dinners, these individuals allegedly provided fraudulent marketing materials to…
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Why stupid clients should not ruin your business model
Unlike lawyers, especially litigators, the business model of a financial advisor is not dependent upon clients being stupid. Instead, financial advisors depend on their clients making smart decisions after full…
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Who Wants To Know How OBA Disclosures Can Save Your Firm?
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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It’s All In The Documentation
In the near 20 years that I have been defending financial advisors against claims, many of which brought by seniors, the biggest issue that I have seen is the failure…
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Don’t Forget This Issue When Dealing With Seniors
It is no secret that FINRA and the SEC are sharply focused on issues regarding elder clients, including severe disciplinary action. There is another elder “issue” that must be…
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Don’t Forget This Data Security Risk
In a recent SEC enforcement action, a registered representative was suspended for 6 months and fined $75,000 for, among other things, forwarding confidential client information from his personal email to…
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It is never too late to learn about risk avoidance
Client relationships and expectations can be the source of success and liability at the same time. Ernie Badway and I will be speaking on May 17 in New York City…
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