SEC Compliance

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
Continue Reading Take Away From The NSCP New York Regional Conference

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
Continue Reading Why Face-to-Face Meetings Are Necessary for Proper Supervision

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
Continue Reading Why A Free Dinner Is Never Really Free

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
Continue Reading Why stupid clients should not ruin your business model

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
Continue Reading Who Wants To Know How OBA Disclosures Can Save Your Firm?

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
Continue Reading Don’t Forget This Data Security Risk

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
Continue Reading It is never too late to learn about risk avoidance