Avoid Broker-Dealer Consolidated Report Enforcement Actions

Are Your Internal Controls, Written Procedures and Supervisory Reviews Enough? If you have reviewed the enforcement actions filed by FINRA related to the use of consolidated reports by broker-dealers, you are probably wondering if you are doing enough to protect your firm.  Here is what you need to know to help make that determination. Consolidated… READ MORE

FINRA Seeks Feedback on Business Continuity Plans

FINRA is currently seeking feedback on its Business Continuity Rule, including if firms have activated their business continuity plans and whether the costs of creating, maintaining or updating such a plan outweigh the benefits.  Feedback is due April 26, 2019. What makes an effective Business Continuity Plan? An effective plan can create loyal customers by… READ MORE

NASAA & FINRA Reports Point to Regulatory Expectations for Heightened Supervision

FINRA’s 2019 Risk Monitoring and Examination Priorities Letter was released last week. While the letter’s second paragraph lists areas of focus which are detailed throughout the report, the third paragraph includes a brief statement about how FINRA will focus on risk related to associated persons with a “problematic regulatory history”.  Where there was not a… READ MORE

Regulatory Actions – ICOs and Digital Trading

Regulators in the digital asset space are focusing a significant amount of attention to Initial Coin Offerings (ICOs) and digital asset trading.  Their activities have included addressing the lack of transparency of exchanges that trade digital assets, jurisdictional issues, and the need to consider registration or qualifying for an exemption for ICOs and cryptocurrency-related investments…. READ MORE

Digital Assets and State Regulatory Challenges

One of the challenges for firms regulated by states is the state’s autonomy to both draft and enforce their own laws It is important to be aware of the regulations in any states where you may be conducting business, including the offer or sale of digital assets. A review of state regulations reveals one common… READ MORE

Cryptocurrencies and the Regulatory Challenges Around Them

The complexity and global popularity of cryptocurrencies, or digital assets, has initiated cooperative efforts between the SEC and CFTC to understand and regulate these products. The agencies have jointly testified before Congress and displayed interest in developing meaningful regulations; both agencies have promised additional working groups to pursue joint regulations. On January 24, 2018, the… READ MORE