While it is pretty likely that anyone reading this is already familiar with the Wells process, I am going to start with a short history lesson.
Way back in 1972, the SEC created an Advisory Committee to take an objective
While it is pretty likely that anyone reading this is already familiar with the Wells process, I am going to start with a short history lesson.
Way back in 1972, the SEC created an Advisory Committee to take an objective…
I have watched enough medical shows over the years, from the awesome St. Elsewhere to the never-ending Grey’s Anatomy, to have heard umpteen times that the Hippocratic Oath includes the admonition that doctors “do no harm.” While, apparently (according to…
When I am engaged to defend a case, whether it’s a customer arbitration or a regulatory complaint, my clients typically get to the point, sooner or later, where they ask me two questions: (1) what do I think about their…
So, after all the hubbub about how Reg BI was going to turn the brokerage industry on its head, given the new standard of conduct – more like that of a fiduciary – that it was imposing on BDs and…
As the song goes, time keeps on slipping, slipping, slipping into the future. While Steve Miller may not have had FINRA and the SEC in mind when he wrote that lyric, the shoe certainly fits. Because here’s the thing about…
It’s always exciting to watch something that you just know will be deemed by later generations to be an historic event. I mean, I distinctly remember watching Neil Armstrong on TV taking his first steps on the moon, or the…
About a month ago, the SEC announced a settlement in a modest little case that has, nevertheless, managed to garner a lot of attention. This is a result of the fact that one of the respondents was the CCO, i.e.,…
Last week I posted a blog about the dangers of not heeding findings made during a regulatory exam, at least findings of clear, undisputable compliance issues that cannot be meaningfully defended. Today I am writing to highlight a corollary rule:…
There is no question in my mind that the quality of FINRA examiners is a bit uneven. Some are smart and insightful and helpful; others are, well, not. Most of the time, they do know what they’re talking about. That…