December 5, 2015
Not all customer communications are necessarily "complaints;" and, not all complaints pertaining to customer accounts are prepared and sent by the customer. Two seemingly obvious point. Ahhh . . . but it's how we interpret the underlying facts and circumstances that often makes all the difference in Wall Street regulation. Similarly, who is responsible for detecting an event that doesn't need to be reported or one that does may often explain why a compliance person is the Chief Compliance Officer versus a mere in-house examiner or why one industry lawyer is paid $250 an hour and another $600 an hour. Then again, there are a lot of morons who rise to managerial ranks and who has not heard the horror stories about over-priced lawyers? READ
The SEC Fears The Email Privacy Act
Currently under consideration before the House of Representative's Committee on the Judiciary is the Email Privacy Act, which seeks to amend portions of the Electronic Communications Privacy Act. At issue is the competition between your civil rights to engage in free and protected speech versus the legitimate need of government to access electronic communications for regulatory and criminal enforcement matters.
Submitted for your consideration is a thought piece. Pointedly, I express no preference for either side of the developing debate. The issues and disputes are what they are. As publisher of the BrokeAndBroker.com Blog, I merely present this article with the hope that it prompts you to think, to ask questions, and to consider how you personally come down on the topic. READ
Wall Street regulation can be a funny thing at times. As a recent FINRA settlement shows, self regulation may often be indistinguishable from an animated sitcom: all we need is Fred, Barney, Wilma, and Betty . . . oh, okay, sure, let's toss in Dino too. Instead of a meaningful conclusion to two settlements, FINRA sort of presents us with something akin to laughable hi-jinks in Bedrock City replete with a Yabba Dabba Doo send-off. READ
The joyous sounds of a non-profit choral. Enter, stage left, a registered rep who serves in an uncompensated role as Treasurer and an executive director. Exit, stage right, a wad of cash. Lower curtain. FINRA lowers the boom. READ