Blog
Form U4 Disclosure Obligations
As members of the securities industry, we have all completed and filed a Form U4 – some of us have done it multiple times. But, did you ever consider how important it is to keep your Form U4 disclosures current to avoid enforcement action for failing to disclose material information? [...]
NASD Rule 3050: Transactions by Associated Persons
Those associated with broker-dealers are put in a position where they can easily commit financial crimes. We watch it played out in movies and we see it happening in real life. One preventative measure firms should take is to establish sound supervisory practices that require oversight of all associated persons’ [...]
OFAC Screening of Existing Clients and Third Parties
On July 6, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added North Korean leader Kim Jong Un and other officials to the list of Specially Designated Nationals and Blocked Persons (“SDN List”) for human rights abuses. While it should not be terribly surprising that [...]
Business Continuity and Transition Plans for RIAs
The Securities and Exchange Commission (“SEC”) recently proposed a new rule that would require registered investment advisers (“RIAs”) to adopt and implement written business continuity and transition plans. The proposed rule is designed to ensure that RIAs have plans in place to address operational and other risks related to a [...]
Rick Control Assessment Surveys due July 20
Around June 1, 2016, active FINRA member firms should have received an email asking them to take part in an individualized Risk Control Assessment Survey (“RCA Survey” or just simply “RCA”). The deadline for the RCA survey this year is Wednesday, July 20, 2016. But what, exactly, is the RCA [...]
AML-CIP Requirements for Private Placement Transactions
The world of private placement transactions is one that is highly scrutinized by both FINRA and the SEC. It seems that with all of the Ponzi schemes and actions for misappropriation of investor monies, private placement transactions are always on the regulators’ exam priorities lists. With that in mind, it [...]