Month: July 2020

How to Answer a FINRA Rule 8210 Inquiry

By Christopher D. Warren / July 31, 2020
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So, you got a letter. From FINRA. It’s about an examination. It’s a Rule 8210 letter. Now what? When you get a Rule 8210 letter from FINRA, it’s serious. This letter is telling you FINRA is launching an investigation, which you, as a registered person of FINRA, are – in some way, shape, or form…

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Securities Law: What Investment Advisors Need to Know About New SEC Limits on Disgorgement

By Christopher D. Warren / July 23, 2020
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On June 22, 2020, a ruling by The U.S. Supreme Court placed new limits on the Securities and Exchange Commission’s (SEC’s) practice around disgorgement – which forces defendants to surrender profits obtained through fraud as part of its enforcement of investor-protection laws in federal courts. According to the ruling, while the SEC can continue to…

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SEC Proposes Amendments for Institutional Investment Managers

By Christopher D. Warren / July 10, 2020
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The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to update the reporting threshold for institutional investment managers and make other targeted changes. The threshold has not been adjusted since the Commission adopted Form 13F over 40 years ago.

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Global Pandemic or Not, Regulation BI is Here – Here Is FINRA’s Guidance

By Christopher D. Warren / July 10, 2020
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Despite the devastating effects of the Covid-19 pandemic on the country and the economy, on June 30, 2020, the United States Securities and Exchange Commission (“SEC”) chose to move forward and implement Regulation Best Interest (“Reg BI”), under the Securities Exchange Act of 1934. Shortly, thereafter, the Financial Industry Regulatory Authority (“FINRA”) issued its own…

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