From “Don’t panic” to “So once you do know what the question actually is, you’ll know what the answer means” to “I don’t know what I’m looking for . . .” to “Life’s
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Not the Same CAT
I do not think that it is an exaggeration to write that historically the public’s view of securities trade reporting has been a collective yawn. (In fact, that sentiment may also be true for industry participants – until, of course,…
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 5
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then…
It Is Still Art
In April 2024, the Securities and Exchange Commission’s Division of Examinations (“EXAMS”) posted another Risk Alert concerning the Marketing Rule (Advisers Act Rule 206(4)-1). This was EXAMS’ third Risk Alert about the rule, following those it published in…
Bigger Than Me
Time is a valuable – and quickly fleeting – commodity. In my head, my wife and I just brought our youngest home from the hospital, but the reality is that we will be staring at an empty nest very soon. …
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 4
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then…
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 3
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then…
A Carbon Copy Unlike Any Other
ATTENTION broker-dealers that post order routing reports pursuant to SEC Rule 606(a): You have a new reporting obligation. Starting with the Rule 606(a) report for the second quarter this year — which, of course, is due on or before July…
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 2
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then…
Tips from The Hitchhiker’s Guide to the Galaxy for Responding to a Regulatory Exam – Part 2
Your day was going great. You helped a client with a particularly complex situation. Another client submitted the paperwork to transfer accounts to your firm. You did not have to deal with a bulldozer trying to demolish your home. Then…