2020 SEC Examination Priorities Released

The Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (OCIE) released their 2020 Examination Priorities Letter on January 7, 2020.   While every area is important, when you read this in context of prior releases, most of the priorities are the same; however, there are some evolving priorities as well. Regulation Best… READ MORE

Is Your Compensation Structure Ready for Reg BI?

If you’re a broker-dealer that is just beginning your Reg BI implementation process, you should quickly review your compensation plan to understand what changes (if any) need to be made to your payout structure to be Reg BI-compliant.  Make sure your payroll team is thinking about how a mid-year amendment is going to work if… READ MORE

Digital Assets – Where Are We Now?

Last week, JP Morgan announced the launch of “JPM Coin.”  We thought it would be good to recap our posts over the past year on the topic of cryptocurrencies and coin offerings and update you on the current state of this market.   As 2018 began, the market capitalization for cryptocurrencies and other digital assets had reportedly exceeded… READ MORE

The Custody Dilemma for Digital Assets

There are many questions that must be answered to understand the risks for broker-dealers and investment advisors who are considering a business mix that includes digital assets. Examples that hit at the core of how firms operate are custody for investment advisors and a similar topic of possession and control for broker-dealers. Unfortunately, for those… READ MORE