Joshua Klein’s Post

#selectivedisclosure #revenuerecognition #insiderfilings #schedule13D #esg #directorindependence #potentialmarket #whistleblower protection enforcement actions, new SEC #Edgar filing logistics, #CTA, shortened deadlines for #investor SEC filings, #Delaware law changes, and thoughts for #10K / #10Q

How to Avoid Violating FINRA Rule 3280 Steering through the complexities of financial regulations can be a formidable challenge, particularly when dealing with rules like FINRA Rule 3280. This rule governs private securities transactions by associated persons of a FINRA member firm, making it crucial for financial professionals to fully understand and comply with its requirements. https://lnkd.in/g8xbeCNT #finra #finrarule3280 #investorprotection #bhseclaw

How will you meet the requirements of the new Restricted Activities and Preferential Treatment Rule? Watch the Gen II #SEC #PrivateFund Advisor Rules Panel and stay updated on the latest insights into SEC regulations for fund #compliance regarding the Quarterly Statement Rule. Watch now: https://bit.ly/4biBeDn

Attention, broker-dealer friends: FINRA recently sent a message to the industry by issuing two CAT reporting AWCs in one day. Notwithstanding public comments by FINRA acknowledging that there are "tons of problems that people raise with CAT," and despite ambiguity about the what the "maximum Error Rate" is for CAT violations, FINRA is not holding back in bringing these cases -- and with hefty sanctions, to boot. Read my and Christopher J. Kelly's take at the link below. #finra #securitiesenforcement #brokerdealers

Without commenting on the brokerage in this particular case, this definitely presents a much more important commentary on the relationship between an SRO and the regulator they extend. It's a lot like the problem with volunteers in a community organization -- when you never technically hired them nor are paying them, it's really difficult to fire them or even put them on a performance improvement plan. We'll be watching along as David V Duccini, Eddie Tobler and a few others have a field day with this story.

I always enjoy some light compliance reading in the morning and this is a fine example. It seems like there further I go in my career the more my disdain for FINRA grows, and this is a prime example why. Regardless of anyone's personal thoughts about the ownership of Alpine there has to be a uniform application of laws and due process tied to any process that might/will affect a business. In the last 10 to 15 years it has become standard process for FINRA to want to put small broker dealers out of business. If you don't believe that please do go fact check the decline in BD's over the past decade. Perhaps also go check out the association of those that went out of business with career ending fines and violations applied by FINRA. With that being said though why do I care? I voluntarily gave up my registration and licensure due to their arduous review practices and never ending scare tactics regarding OBA disclosure. I care because for some really contrived reason FINRA has control of the 15C-211 process to illicit the creation of a ticker symbol for issuers that desire to trade on the OTC Markets Group. They also have oversight when it comes to an kind of corporate action, from name changes to cash dividends to mergers. Unfortunately for all my issuer clients there is no one FINRA that has any understanding of legal compliance on a state or federal level and then applies it to the issuers notification of an event. This creates unduly long processing times for events, delay in notifications, and unfortunately as I've seen far too many times damage to shareholders and impairment to their return due to unforced delays because of incompetence. I wish it weren't like this....perhaps there should be more than one main SRO to cover such a broad and expansive swath of the market. Would love to hear everyone's input! What do you guys think aaim and David V Duccini? #finra #sec #compliance #otcmarkets #ipo #goingpublic

What are the latest developments in FINRA enforcement, regulation and dispute resolution? Read more in the April issue of Bracewell’s FINRA Facts and Trends. #FINRA #enforcement

FINRA Rules: Allegations of Selling Away Have you ever heard of selling away? It’s something that can get financial advisors in big trouble with FINRA, the Financial Industry Regulatory Authority. This article will explain what selling away is, why it’s a problem, and what the consequences can be. We’ll also review some important FINRA rules you need to know about to avoid any issues. https://lnkd.in/gGbTR9ns #investorprotection #sellingaway #finra #finraarbitration #bhseclaw

SECURITIES ENFORCEMENT: An Unofficial Guide to FINRA’s 2024 Enforcement Statistics by Lisa M. Colone & Christopher J. Kelly Read more to find out a breakdown of FINRA's 2024 Letters of Acceptance, Waiver, and Consent (AWC) against firms: https://loom.ly/KZ3yfFU

I may share the byline, but credit really goes to Christopher J. Kelly and our spectacular colleague and friend, Joanne Young, who together painstakingly reviewed and categorized every firm AWC issued by FINRA in 2024. This Client Alert sets forth the average and median fine imposed in 2024 (broken down by firm size), the most commonly charged violations, and much, much more. Check it out! #CSGLaw #finra #securitiesenforcement #brokerdealers