FINLAW: The SEC proposes a finder exemption to broker-dealer registration
- By: admin
- Oct 15
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Last week, the SEC proposed a finder’s exemption to foster capital raising for small businesses. The proposal, which is not yet final, provides a safe harbor for finders to assist issuers in raising capital from accredited investors. The proposal creates two tiers of finders (Tier I and II), and the requirements a finder must meet
Read MoreFINLAW: What should you do when you receive a Rule 8210 request from FINRA?
- By: admin
- Feb 19
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It frequently happens as follows: a registered representative or associated person of a broker-dealer (RR) receives a Rule 8210 letter from FINRA requiring that she respond to questions or worse, appear before FINRA to provide testimony under oath (OTR). Any hope that your departure from a broker-dealer that marked up Form U5 with unsavory details
Read MoreFINLAW: Peirce’s proposed safe harbor for three years of crypto (almost) regulatory immunity unlikely to become reality; Telegram Court proceeding presents opportunity for clarification of law
- By: admin
- Feb 10
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SEC Commissioner and Crypto Mom Hester Peirce completed her adoption of the crypto industry four days ago. Peirce single handedly proposed a safe harbor for crypto/digital asset offerings excusing all regulatory violations except fraud. The safe harbor proposal provides regulatory immunity except for fraud to crypto offerings for a period of three years to enable
Read MoreFINLAW: Unregistered persons who raise capital continue to be a top SEC enforcement priority
- By: admin
- Jan 28
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In what has become a typical announcement, the Securities and Exchange Commission (SEC) announced yesterday that it has filed three more actions against persons who acted as unregistered broker-dealers in violation of Section 15(a)(1) of the Securities Exchange Act of 1934. While reviewing these cases, I observed the SEC announced yet another case this morning.
Read MoreFINLAW: Asking your customer to move their brokerage account MAY violate Regulation Best Interest (“Regulation BI”)
- By: admin
- Jan 19
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FINRA member Firms are required by June 30, 2020, to comply with Regulation BI. Regulation BI is a rulemaking package that one regulator described as a “once-every-several decades” rule.[1] Regulation BI mandates four essential obligations which will transform the way retail broker-dealers (“BDs”) do business in the United States. These include the Disclosure obligation, Care
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