Heidi continues to stay on top of developments relating to Reg BI. – Alan Just in case you’ve not yet seen them, both the SEC and FINRA, over the last week or so, have released a series of documents that touch, partly or entirely, on Reg BI (which everyone knows they must comply with by the end of June 2020).  First, we have the 2020 Priorities Letters which, in addition to the evergreen priorities…

The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a $1.4 million fine.  Their offense?  They each violated FINRA’s supervisory rules because for a number of years, dating all the way back to 2014, none of them had adequate written supervisory procedures regarding UTMA and UGMA accounts.  Specifically,…

From time to time, I have lamented that FINRA does not hold itself to the same lofty standards to which it holds its members.  I realize I am painting with a broad brush, as there are lots of folks at FINRA who do a great job, who are easy and reasonable to deal with, and who don’t play games.  But, that is not the case across the board.  And every once in a while, FINRA…

My partner, Heidi VonderHeide, has busied herself these last few months learning everything she can about Reg BI.  Happily, here is her post on the subject, and it doesn’t predict gloom and doom in the new year as that regulation is implemented.  – Alan Just before the Holidays, I attended FINRA’s one-day Reg BI seminar in Washington D.C., where member firms and regulators (but primarily the SEC) discussed the new rule and what they hoped it…

Between the usual holiday season madness and a recent trial, I have been a little tied up lately.  Happily, Chris Seps has stepped up with this excellent piece on Reg BI. – Alan   My young boys will sometimes chase me around the house, catch me, and yell “gotcha” as they drag me off to their pretend jail.  No matter how much I plead that I’ve done nothing wrong, I always end up in jail,…

This post is about Reg BI, but if you really want to learn about it, as opposed simply to listening to me gripe, I urge you to register for the webcast that my partners Heidi VonderHeide and Rob Betman will present on Wednesday, December 11, 2019, at 2:00 PM EST.  It is just one of four financial services webcasts that Ulmer & Berne is hosting in December.  As previously noted, they are free, and not only that,…

In December, Ulmer & Berne is hosting four financial services webcasts, the first of which I will be presenting along with my partner, Michael Gross:  FINRA 2019: A Look Back, and Thoughts About What Lies Ahead (Wednesday, December 04, 2019, 2:00 PM EST).  The others are The Anatomy of a Whistleblower Action: Procedure, Practice Pointers, and Avoiding Pitfalls (Thursday, December 05, 2019, 2:00 PM EST); Hot Topics in SEC Regulation and Enforcement (Wednesday, December 11,…