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New Year, Old Problem: Broker-Dealers Should Evaluate Their Supervision of Personal Device Use

Many companies that transitioned to a work-from-home environment in early 2020 may have reasonably anticipated a return to the normalcy of in-office operations by the end of the year. Yet as 2021 commences, remote work has...more

Another Cop on the Beat? CFP Board Signals Increased Enforcement Focus

Financial advisors have long used the Certified Financial Planner designation as an indicator to potential clients that they meet high standards of professionalism and ethics within their field. The Certified Financial...more

OCIE Finds Supervision Failures at Multiple-Branch Office Investment Advisers

On November 9, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced the results of its examination of nearly 40 SEC-registered investment advisers that operate multiple branch offices (the...more

Ready or Not, Prepare to Start Answering Questions About Reg BI Compliance

On June 5, 2019, the SEC adopted Regulation Best Interest (“Reg BI”), which requires broker-dealers and associated persons to make recommendations regarding securities transactions (or investments involving securities) that...more

North American Securities Administrators Association (NASAA) Releases Model Cybersecurity Rule

On May 21, the North American Securities Administrators Association (NASAA)—an organization comprised of 67 securities regulators within the United States (all fifty states as well as districts and territories), Canada, and...more

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

Between a Rock and a Hard Place: SEC Disclosure Analysis in Light of Yahoo Settlement

On April 25, the Securities and Exchange Commission announced a settlement with Yahoo that constituted its first enforcement action against a public company for failing to disclose a data breach. This settlement...more

FINRA Regulatory Notices Demonstrate Focus on Excessive Trading, Supervision

While the securities industry focused on parsing the Securities and Exchange Commission’s recently proposed best-interest standard and speculating about the ultimate fate of the Department of Labor’s vacated fiduciary rule,...more

FINRA Enforcement: New Direction for the Regulator

With new leadership at the helm of the Financial Industry Regulatory Authority (FINRA), the broker-dealer industry’s primary self-regulator, and the FINRA Enforcement Department, there is an opportunity for real and...more

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