FINLAW: What should you do when you receive a Rule 8210 request from FINRA?
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
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
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”)
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
Read MoreFINLAW: SEC Issues First No Action Letter Regarding Tokenization of Digital Asset by TurnKey Jet that is NOT a Security, April 3, 2019
See my comments to CROWDFUND INSIDER article relating to the SEC’s Turnkey no action letter. https://www.crowdfundinsider.com/2019/04/146005-sec-issues-first-no-action-letter-regarding-tokenization-of-digital-asset-by-turnkey-jet-that-is-not-a-security/ SEC Issues First No Action Letter Regarding Tokenization of Digital Asset by TurnKey Jet that is NOT a Security April 3, 2019 @ 11:05 am By JD Alois The Securities and Exchange Commission (SEC), Division of Corporate Finance, has issued its
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