SEC’s 2019 Priorities Should Become Your Firm’s Priorities

SEC Priorities

Every year, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) publishes its examination priorities to address risks that are a potential threat to investors or the integrity of the U.S. capital markets. On December 20, 2018, OCIE released its 2019 examination priorities, which are available at These priorities...

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FINRA’s 529 Plan Share Class Initiative to Self-Report

finra 529

FINRA recently announced its 529 Plan share class self-reporting initiative in Regulatory Notice 19-04. This initiative is consistent with FINRA’s efforts to employ remote surveillance and to have broker-dealers promptly remedy potential supervisory and suitability violations relative to share class recommendations for 529 Plans. Broker-dealers are encouraged to self-report and...

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FINRA Issues Organizational Deficiencies

Finra deficiences

FINRA recently issued Organizational Deficiencies in Web CRD to several member firms seeking corrections to responses provided in item 10A: Control Affiliates of Form BD. Question 10A reads: “Directly or indirectly, does applicant control, is applicant controlled by, or is applicant under common control with, any partnership, corporation, or other...

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A Dark Desert Communications Highway


Ask people for a line from the Eagles song “Hotel California” and you can expect, “You can check out any time you like, but you can never leave.”  The famed verse comes 4:15 into a 6:30 song (an eternity by today’s standards), it is the last of the lyrics, and...

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