The Importance of Effectively Monitoring Gifts and Entertainment – Part 1: ERISA
Gifts and entertainment can establish goodwill between securities professionals and their clients. However, some gifts and entertainment benefits can be too frequent or so excessive as to give rise to an appearance of improper influence. To prevent improprieties, governmental agencies … Read More
Broker Dealers Will Soon Be Required To Search For Lost Securityholders
On December 21, 2012, the Securities and Exchange Commission (“SEC”) unanimously approved a Draft Final Rule requiring broker-dealers to conduct searches for holders of securities with whom they have lost contact. A similar rule already applies to recordkeeping transfer agents, … Read More
FINRA Considering Rule for Bonus Disclosure
The Financial Industry Regulatory Authority Inc. (“FINRA”) Board of Governors voted to propose a rule during the December board meeting that would require brokers to disclose their recruitment incentives to customers. The suggestion is obviously getting a sharp reaction from … Read More
Compliance End-of-the-Year Checklist Update
Nov. 2012
“Cloud-Based” File Sharing Gaining Momentum
According to a poll released this month by “DataMotion,” whereby more than 200 IT and business decision-makers across the U.S. and Canada were questioned about their corporate email and file transfer habits as they relate to the personal information of … Read More
FINRA Continues to Scrutinize Nontraded REITs
Over the past couple of years, examiners with the Financial Industry Regulatory Authority, Inc. (“FINRA”) have focused on how broker-dealers sell nontraded real estate investment trusts (“REITs”). Specifically, Susan Axelrod who is the Executive Vice President of Member Regulation Sales … Read More
Coordinated Examinations Identify Top Broker-Dealer Compliance Violations
Sept. 2012
Accomplice in Insider Trading Comes Clean and Receives Lenient Penalty
In an SEC investigation, Kenneth F. Wrangell was contacted by SEC Investigators regarding his suspicious trading activities regarding Mercer Insurance Group, to which Wrangell offered his full and expedient cooperation. His cooperation resulted in the SEC obtaining details of his … Read More
The Importance of Performing Due Diligence
Aug. 2012