Finding A Way.

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...

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...

Taking It To A New Level — SEC Awards Whistleblower Unprecedented $14 Million

The Securities and Exchange Commission awarded more than $14 million to a whistleblower earlier this month.  The information led to an enforcement action that recovered substantial investor...

Crowdfunding, the SEC and The New Rules—What Finally Came Down Today

The wait and speculation is over for now.  Today the SEC proposed rules under Title III of the JOBS Act that allow start-ups and small businesses to...

Proposed Disclosure Rules Will Not Delay Lifting of General Solicitation Ban

SEC Chair Mary Jo White recently confirmed that the SEC will not delay the lifting of the ban on general solicitation over the additional disclosure rules proposed...

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