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
Regulation by Footnotes
Dec. 2012
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 Computing Considerations for Financial Firms
Oct. 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
Update: California Private Fund Adviser Exemption is Effective
A permanent private fund adviser exemption has been adopted by the California Department of Corporations (the “Department”). The exemption was effective August 27, 2012, following public comments first received between February 20th and March 25th, 2012. Several amendments were made … Read More
DOL Inquiry Focuses on Financial Advisers at Breach under ERISA
The Department of Labor has brought an inquiry whether JPMorgan Chase & Co. committed a fiduciary breach under the Employee Retirement Income Security Act of 1974. The inquiry is related to a stable-value fund and could target financial advisors. The … Read More
