PLAY BY THE REGS

In response to an increase in the number of registered investment advisers outsourcing their compliance function to unaffiliated third parties, the SEC’s Office of Compliance, Inspections and Examinations (OCIE) created an Outsourced CCO Initiative and conducted 20 inspections of advisers specifically focused on identifying areas of concern and weakness in such arrangements.  On November 9, … More The SEC Staff Issued Guidance on Outsourcing Compliance Functions – 5 Questions to Ask

Last week the SEC approved Title III, thereby giving non-accredited investors (those who have a net worth of less than $1 million, including spouse, and those who earned less than $200,000 annually or $300,000 with spouse in the last two years) the opportunity to invest in start-up companies in early 2016. Ideally, opening the gates to non-accredited investors will … More Top 10 Things to Know About the SEC’s Equity Crowdfunding Rules

On October 26, 2015, the Securities Exchange Commission (SEC) announced that it will consider whether to adopt rules and forms under Title III of the Jumpstart Our Business Startups (JOBS) Act, what has become known as the “Crowdfund Act.” Three years ago, President Obama signed into law the JOBS Act, which is comprised of seven … More It’s Time to Open the Gates for Equity Crowdfunding

On September 23, 2015, FINRA issued an investor alert about smart beta indexes, “essentially any index that is based on measures other than weighting by market capitalization.”  Unlike the most widely known indexes, such as S&P 500, which use a company’s market capitalization to establish an index, smart beta indexes rely on alternative methodologies, such … More FINRA’s 6 “Smart” Questions for Smart Beta

Last month, FINRA issued a Targeted Exam Letter to about a dozen retail broker-dealers seeking detailed information about a broad range of compensation practices, including payout grids, recruiting incentives, mutual fund fees, and income received from product sponsors.  The letter requests firms to identify and describe how compensation is determined and governed and to explain … More FINRA’s Conflicts of Interest Review on Broker Compensation: It’s Time to Get Under the Hood

This Blog is being established by the Financial Regulatory and Compliance practice group at Shulman, Rogers, Gandal, Pordy & Ecker, P.A., a full-service law firm of 100+ attorneys located in suburban Washington, D.C.  The firm has a well-established Business and Financial Services practice which includes a group of practitioners who concentrate on the broker-dealer business, … More Welcome to Play by the Regs