Blog
Outside Business Activity Disclosure Form Best Practices
When creating an outside business activity (“OBA”) disclosure form, it's important to understand how FINRA defines an outside business activity and what information must be disclosed. Firms can request additional information however it is recommended that Firm’s ensure the required information is collected, reviewed and approved by the Firm’s designated [...]
NASAA Reveals Top Investor Threats for 2022
On January 10, 2022 the North American Securities Administrators Association (NASAA) released its annual list of top investor threats for 2022 and urged caution before purchasing popular and volatile unregulated investments – especially those involving cryptocurrency and digital assets. NASAA also announced guidance for investors, including steps to take to [...]
FINRA Announces Rule 4111 (Restricted Firm Obligations) Evaluation Date
In an Information Notice released February 1, 2022, FINRA announced the first “Evaluation Date” for the new Rule 4111 (Restricted Firm Obligations) on June 1, 2022. Rule 4111 went into effect on January 1, 2022, and addresses firms with a significant history of misconduct. More specifically, it requires member firms [...]
2022 & 2023 Continuing Education Requirements for IARs
In November of 2020, the North American Securities Administrators Association (“NASAA”) adopted a new rule (PDF) that will require Investment Advisor Representatives (“IARs”) to complete 12 credit hours of Continuing Education annually, 6 for IAR Ethics and Professional Responsibility Requirements and 6 for IAR Products and Practice Requirements. This will [...]
Changes to FINRA Rule 2165: Financial Exploitation of Specified Adults
FINRA has adopted amendments to Rule 2165 (Financial Exploitation of Specified Adults) to permit member firms to: (1) place a hold on a securities transaction (in addition to the already-permitted hold on a disbursement of funds or securities) where there is a reasonable belief of financial exploitation; and (2) extend [...]
Considerations for FinCEN 314(a) Policies and Procedures
The Financial Crimes Enforcement Network (FinCEN) is a program under Rule 31 CFR Part 1010.520 that requires certain financial institutions to search their records and identify if they have responsive information with respect to the particular investigative subject. This provides a service to law enforcement by providing an additional layer [...]