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Considerations for Dually Registered Firms
Recently it was reported that a dually registered broker-dealer/investment adviser was assessed a
$125,000 civil penalty by the SEC and was required to reimburse clients who were overcharged transaction fees of $369,000. In addition to the fees paid by the firm, its chief compliance officer is required to pay... |
By: Kathryn Langridge
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FINRA Annual Conference-Compliance Considerations for Social Media
The 2011 FINRA conference in Washington, D.C., on May 23-25 was attended by more than 900
professionals from the financial field. Wrapping up the first day of the conference was a session titled, “Compliance Considerations for Social Media,” which drew a large audience... |
By: Rob Marchinkowski |
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Proposed Rule Change Regarding
Continuing Education Sessions
and Qualification Examinations
Currently, if one of your registered representatives schedules an appointment for a qualifying exam (i.e.,
Series 7 or Series 63) or a Regulatory Element continuing education session, as long as the registered representative arrives on time or cancels the appointment two business days in advance, your firm will not
be subject to additional service charges...
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FINRA Expectations in Evidencing Capital Contributions
In working with our clients and new BD applicants, we have found there is often confusion in regards to the proper documentation of capital contributions. FINRA looks for four major types of documentation to be included in evidencing capital contributions... |
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Adviser Transition Delayed until March 30, 2012
At its meeting on June 22, 2011, the Securities and Exchange Commission (“SEC”) officially adopted rules
that give advisers with assets under management between $25 million and $100 million until March 30, 2012 to register with the appropriate states... |
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New Pay-for-Performance Rule
The Securities and Exchange Commission has proposed a rule to raise the net worth thresholds that would need to be met before investment advisers can charge their clients performance fees. This rule proposal, some of which was mandated by the Dodd-Frank Reform and Consumer Protection Act, is the latest of the SEC’s efforts to protect investors... |
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Adviser and Self-Regulations: A Good Idea?
As many of you already know, FINRA has taken great strides to position itself as the self-regulatory organization (SRO) for investment advisers. Since the January release of the SEC’s report on adviser oversight, clients have approached Regulatory Compliance... |
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