The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more
4/24/2024
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Electronically Stored Information ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
Insider trading is a front-and-center issue for the SEC, and consequently must be for financial services firms as well. The SEC included misuse of material non-public information (MNPI) on its list of 2022 exam priorities for...more
5/11/2022
/ Bank Secrecy Act ,
Broker-Dealer ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Insider Trading ,
Material Nonpublic Information ,
Risk Alert ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Suspicious Activity Reports (SARs)
Key Takeaways:
..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more
8/18/2021
/ Books & Records ,
Broker-Dealer ,
Business Continuity Plans ,
Compliance ,
Corporate Governance ,
Cybersecurity ,
Data Breach ,
Data Security ,
Due Diligence ,
Financial Industry Regulatory Authority (FINRA) ,
Internal Controls ,
New Guidance ,
Outsourcing ,
Professional License ,
Risk Management ,
Supervision ,
Third-Party Service Provider
In case you were wondering if you can still push off finalizing your Form CRS filing, posting it on your website and delivering it to clients, the SEC has read your mind and answered loudly: no more! On Monday, the SEC...more
Given the continued popularity of recommending wrap fee programs to clients, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“DOE”) recently released a Risk Alert dated July 21, 2021, wherein it...more
FINRA recently filed a Complaint against a Chief Executive Officer and Chief Compliance Officer of a registered broker-dealer alleging, among other things, that the individual caused the broker-dealer to have wide-ranging...more
Being a small business owner is tough. You often wear several hats and juggle multiple responsibilities while you try to build a successful business. This is especially true for small financial services firms that are subject...more
On September 23, 2020, the U.S. Securities and Exchange Commission (“SEC”) entered an Order Instituting Administrative and Cease and Desist Proceedings (“Order”) against a broker-dealer, JonesTrading Institutional Services,...more
The SEC's Office of Compliance and Examinations (OCIE) issued a risk alert on July 10th about its observation of an apparent increase in sophistication of ransomware attacks on SEC registrants, including broker-dealers,...more
A recent Securities and Exchange Commission (“SEC”) order imposed sanctions on a financial institution for failing to reasonably supervise a representative’s conduct. In its findings, the SEC highlights the institution’s...more
4/15/2019
/ Best Practices ,
Broker-Dealer ,
Financial Institutions ,
Investigations ,
Investment Adviser ,
Policies and Procedures ,
Professional Misconduct ,
Registered Representatives ,
Rule 10b-5 ,
Securities Act ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
On November 21, 2017, FINRA issued Regulatory Notice 17-40 to provide member firms guidance regarding their obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program) in light of the Financial Crimes...more
The SEC recently charged a New York-based broker-dealer, Windsor Street Capital, L.P. (f/k/a Meyers Associates, L.P.) and John David Telfer, who acted as Windsor’s Chief Compliance and Anti-Money Laundering Officer for...more