FINRA Investigations — To Joint Rep Or Not To Joint Rep?

Law360, New York (March 12, 2013, 12:38 PM ET) – Q: Do you understand that your counsel represents both the firm you work for and other individuals in this matter? A: Yes. Q: Do you wish to proceed? A: Umm … yes? This exchange, or something similar, should sound familiar to any lawyer who has been

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FINRA’s 2013 Regulatory Priorities

On January 16, 2013, FINRA Chairman and CEO, Richard Ketchum, spoke at the SIFMA Compliance and Legal Society monthly luncheon about FINRA’s regulatory plans and priorities for the upcoming year.  As set forth below, Mr. Ketchum covered topics that were previously identified by FINRA in its 2013 Regulatory and Examinations Priorities letter, which can be

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Sweep Exams: What, When, Why and How to Prepare and Respond

On December 18, 2012, a panel composed of regulators and industry experts spoke at the SIFMA Compliance and Legal Society monthly luncheon regarding various aspects of sweep exams.  The panel was moderated by C&L Executive Director R. Gerald Baker and was comprised of: William Wollman, Senior Vice President, FINRA; Suzanne McGovern, Assistant Director, U.S. Securities

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Will New Court Ruling Give Troubled Advisors Clean Slate?

FUNDfire, October 5, 2012 Your Q&A is your opportunity to get your questions answered by industry leaders. Q.  What are the main takeaways for advisors of the recent California court ruling on broker-dealers clearing their FINRA records of past customer complaints? – Advisor, high-net-worth focus, California Answered by Dimitri Nemirovsky, the cofounding partner of the

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How FINRA Rule 2111 Affects Fee-Based Accounts

Law360, New York (September 10, 2012, 12:01 PM ET) — The Financial Industry Regulatory Authority’s new suitability rule may well have an unintended positive effect on fee-based accounts for member firms. For some time, member firms have grappled with utilization issues relating to fee-based, or so-called “wrap-fee,” accounts. In certain circumstances, the fees charged to fee-based

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The SEC’s Examinations Program of IAs and Dually Registered Firms

On July 25, 2012, Ken C. Joseph, Associate Director of the New York Regional Office of the U.S. Securities and Exchange Commission, Office of Compliance, Inspections and Examinations (“OCIE”), spoke at the SIFMA Compliance and Legal Society monthly luncheon about the SEC’s examinations program of IAs and dually registered firms. A summary of the presentation

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FINRA’s New Know Your Customer And Suitability Rules

On July 9, 2012, two new FINRA rules are scheduled to go into effect – Rule 2090, “Know Your Customer,” and Rule 2111, “Suitability.”  Rule 2090 is modeled after former NYSE Rule 405(1), “Diligence as to Accounts,” and Rule 2111 is modeled after former NASD Rule 2030, “Recommendations to Customers (Suitability).”  While the new Know

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Above The Law Article About Reyhani Nemirovsky

Reyhani Nemirovsky was recently featured in an article in Above the Law.  Follow the link for more… http://abovethelaw.com/2012/06/size-matters-how-a-bad-economy-means-good-business-for-a-new-boutique-firm/

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Hot Topics in the SEC’s National Exam Program

On May 15, 2012, Carlo di Florio, Director of the Office of Compliance Inspections and Examinations at the U.S. Securities and Exchange Commission (“OCIE”), spoke at the SIFMA Compliance and Legal Society monthly luncheon at the Harvard Club in New York City.  Mr. di Florio discussed Hot Topics in the SEC’s National Exam Program: A

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FINRA Exam Initiatives 2012

On April 24, 2012, Susan Axelrod, Executive Vice President and Head of Member Regulation Sales Practice at FINRA, spoke at the SIFMA Compliance and Legal Society monthly luncheon at the Harvard Club in New York City.  The topic was FINRA’s sales practice concerns and sales practice exam program. Ms. Axelrod covered six areas during her

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