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FINRA Reminds CCOs About Potential Supervisory Liability

FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory responsibilities delegated to them. FINRA recognizes that compliance and supervision are distinct roles that carry different obligations.  FINRA has said that…

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FINRA Reminds Firms of Evolving Definition of “Prompt” Order Execution

FINRA recently reminded firms of their obligation to execute marketable customer orders fully and promptly.  While this seems fairly routine, what’s notable about the reminder is that “prompt” doesn’t necessarily mean what it used to. FINRA Rule 5310 (Best Execution and Interpositioning) requires a firm to “make every effort to…

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SEC Penalizes 12 Additional BDs and IAs with CRS Failures

On February 15, 2022, the SEC announced settlements with 12 broker-dealers and investment advisers for failing to satisfy their Form CRS obligations.  These settlements come on the heels of 27 settlements last year for similar violations.  While all settlements included both a failure to timely file and deliver relationship summaries,…

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