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609, 2018

What is an Initial Coin Offering (ICO)? – Part I

September 6, 2018|Categories: Digital Assets, FINRA, Fraud, SEC|Tags: , , , , , |

Digital assets such as cryptocurrencies, as well as other crypto coins and tokens, may be offered to investors in the form of an Initial Coin Offering (ICO). But what is an ICO? And why are they such a regulatory hot topic in the securities industry currently? […]

2308, 2018

FINRA Enhances Disclosure Review Process

August 23, 2018|Categories: Broker-Dealer, FINRA, Registrations, Rules and Regulations|Tags: , , , , , , |

As I’m sure you already know from reading our previous blogs on the subject, FINRA Rule 3110(e) (Responsibility of Member to Investigate Applicants for Registration) requires that member firms must “ascertain by investigation the good character, business reputation, qualifications, and experience of an applicant” prior to submitting a Form U4 [...]

1608, 2018

ERA: Exempt Reporting Adviser Qualification – Part II

August 16, 2018|Categories: Exempt Reporting Adviser, Registered Investment Advisers|Tags: , , , , , , , , , |

[Continued from ERA: Exempt Reporting Adviser Qualification – Part I] SEC ERA Registration vs. State ERA Registration Firms with more than $100 million in regulatory AUM (Large Advisers) must register with the SEC unless an exemption is available. Advisers with between $100 million and $150 million AUM solely attributable to [...]

1608, 2018

ERA: Exempt Reporting Adviser Qualification – Part I

August 16, 2018|Categories: Exempt Reporting Adviser, Registered Investment Advisers|Tags: , , , , , , , , , |

Per the Investment Advisers Act of 1940 (the “Advisers Act”), firms who meet the definition of providing investment advisory services generally must register either with the SEC or with state securities regulators. When the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) was signed into [...]

2607, 2018

Cryptocurrency and The Securities Industry

July 26, 2018|Categories: Broker-Dealer, Digital Assets, FINRA, Fraud, Registered Investment Advisers, SEC|Tags: , , , , , , |

Cryptocurrency (also spelled crypto currency) is everyone’s new favorite hot topic. Even if you’ve done no research into the topic, you’ve probably heard of the most (in)famous cryptocurrency: Bitcoin. But what are cryptocurrencies? And how are they affecting the securities industry? […]

1907, 2018

Form U10 and TESS (Test Enrollment Services System)

July 19, 2018|Categories: Broker-Dealer, Examinations, FINRA, Rules and Regulations|Tags: , , , , , |

Since our last post about Form U10, FINRA has implemented the Test Enrollment Services System (TESS). Beginning in June 2017, FINRA began transitioning all non-U4 examination enrollments to TESS and ended the utilization of the Form U10. […]

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