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This biggest issue with the financial services industry is the fact that investment advisers are required to operate at a disadvantage; advisers are defined as a fiduciary while broker dealers…
Last month, the SEC instituted cease and desist proceedings against an AML Officer and CEO of a New York-based investment adviser and broker-dealer due to violations of the Securities Exchange…
An important part of the implementation of any compliance program is the supervision of the firm’s employees and associated persons. A firm’s compliance manual should address policies and procedures that…
Today the SEC announced that three advisers have settled charges for breaching fiduciary duties. Per the SEC, PNC Investments LLC, Securities America Advisors Inc., and Geneos Wealth Management Inc. failed…
In 13 years acting as an auditor in the securities regulation industry it was surprising to find out how few in the industry conducted, and documented, due diligence of the…
FINRA is requesting comments on a proposed new rule for outside business activities and private securities transactions of registered persons. This proposed rule would replace FINRA Rule 3270 (Outside Business…
The Securities & Exchange Commission (“SEC” or the “Commission”) instituted cease and desist proceedings against Financial Fiduciaries, LLC, (“Financial Fiduciaries”) a registered investment adviser located in Wausau, Wisconsin, and Thomas…
Thomas Buck, a dually registered Investment Adviser Representative who worked at Merrill Lynch for 33 years prior to being terminated in 2015, now faces prison following his guilty plea on…
The Securities and Exchange Commission (“SEC”) has announced, under a new Share Class Selection Disclosure Initiative (“SCSD Initiative”), that it will not seek civil penalties against eligible investment advisers who…
Being named as supervisor of any registered investment advisor or broker dealer comes with a great deal of responsibility, and risk. This is why it is very important for all…
FINRA has adopted an amendment to FINRA Rule 4512 (Customer Account Information) (the “Trusted Contact Rule,”), effective February 5, 2018, which requires member firms to adopt protocols for making reasonable…
On December 5, 2017, the Securities and Exchange Commission (“SEC” or the “Commission”) filed a Complaint in the United States District Court for the Southern District of Texas against James…
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