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2712, 2019

Electronic Storage Requirements: Is Your Firm Ready to Go Paperless?

December 27, 2019|Categories: Broker-Dealer, FINRA, Rules and Regulations, SEC|Tags: , , , , , |

Is your small broker-dealer drowning in boxes and boxes of paper? Do you cringe every time you think of storing yet another 50+ page document? Are you interested in exploring the benefits of cloud-based storage? If you answered “yes” to any of these questions, you must first consider your firm’s [...]

1812, 2019

Annual Compliance Requirements: Year-End Priorities

December 18, 2019|Categories: Anti-Money Laundering, Broker-Dealer, FINRA, Registrations|Tags: , , , , , , , , |

It’s that time of the year again! As the fourth quarter ticks by, we have compiled a helpful end of year to-do list to aid small broker-dealers in addressing and closing out important annual compliance requirements. […]

111, 2019

Digital Communications: 2019 FINRA Report

November 1, 2019|Categories: Broker-Dealer, Examinations, FINRA, Rules and Regulations, Social Media|Tags: , , , , , |

In the recent “2019 Report on FINRA Examination Findings and Observations,” one of the topics highlighted was the use of digital communications. This can include a wide range of social media, email, text messaging, and various other digital tools. The regulatory requirements pertaining to the usage of digital communications are [...]

2510, 2019

Fees and Expenses: 2019 SEC Examination Priorities

October 25, 2019|Categories: Examinations, Registered Investment Advisers, SEC|Tags: , , , , |

At the end of each calendar year, the Office of Compliance Inspections and Examinations (“OCIE”) staff of the United States Securities and Exchange Commission (“SEC”) publish a list of topics for the next year’s examination priorities. Not so surprisingly, the first item for the 2019 exam priorities listed is “fees [...]

1710, 2019

Senior Investors: Protecting the Client

October 17, 2019|Categories: Broker-Dealer, Registered Investment Advisers, Rules and Regulations|Tags: , , , , , , |

Today, investment advisers and broker-dealers face many challenges when providing advice to and working for senior investors. Many seniors are living with or approaching diminished capacity due to Alzheimer’s, dementia, and/or other health-related issues. Unfortunately, these health issues create vulnerability for financial exploitation from caregivers, family members, neighbors, friends, medical [...]

1110, 2019

Best Execution: Compliance for Investment Advisers

October 11, 2019|Categories: Best Execution, Registered Investment Advisers, SEC|Tags: , , , |

Under the Investment Advisors Act of 1940 (the “Advisers Act”), Investment Advisers assume a fiduciary responsibility requiring them to seek and obtain the “best execution” for client transactions when trading in client accounts. The United States Securities and Exchange Commission (“SEC”) has outlined this responsibility as “an adviser must execute [...]

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