Finding A Way.

Open for Comment: FINRA’s Funding Portal Rules

With all the noise about the proposed set of rules for crowdfunding the SEC released in October, one piece of the puzzle almost slipped by unnoticed. In...

The Annual Drill—Calculating Regulatory Assets Under Management for Form ADV

While working on the chapter on Regulatory Assets Under Management for my new book about Dodd Frank and the Advisers Act, I realized that now would be...

SEC Issues Guidance on General Solicitation Rules

On November 13, the SEC released Compliance and Disclosure Interpretations (“C&DIs”) for the new rules authorizing general solicitation and advertising for securities offerings relying on Rule 506(c)...

SAC Capital, Insider Trading and the Southern District

It would be old news already if the case had not garnered so many superlatives.  One of the country’s most famous hedge fund managers.  The largest insider...

FINRA Cracking Down on “No Fee” Advertising

FINRA recently expressed concerns about broker-dealers who advertise “free” or “no fee” services for retail brokerage accounts and individual retirement accounts (IRAs). FINRA Rule 2210 requires that...

SEC Examinations Targeting Advisers Who Are Still Waiting for Godot

I have worked with a number of advisers who have never ever been examined by the SEC, not once in their 10 +, 15+, etc. years of...

The NYT Dealbook Conference 2013: Opportunities for Tomorrow

The New York Times Dealbook Conference was one of the most inspiring conferences that I have attended in a long, long time. Maybe ever. The line-up: Curated...

Three Steps to an Effective Whistleblower Program

Everyone should have one. If you need more convincing, please read my post, or any post for that matter, about the record $14 million award the SEC...

FINRA’s Conflicts of Interest Report: Bridging the Great Divide?

FINRA issued a report on conflicts of interest within the broker-dealer industry last month.  It is the result of a review initiated in July 2012 at a...

The SEC and the Chief Compliance Officer, 2013

Mary Jo White recently gave a speech before the National Society of Compliance Professionals that I found noteworthy.  It focused on the role of the Chief Compliance...

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