Blog by Bill Singer WEEK IN REVIEW

May 27, 2017

In Memory of Gregg Allman

This is agent Josh, we were sent by the Acting Director of Federal Bureau of Investigation (Andrew G. McCabe), we are currently in Africa as an FBI/ United States delegate that have been delegated to investigate these fraudsters who are in the business of swindling Foreigners that has transactions in Africa. READ 

Many taxpayers lack the funds to pay their taxes when the time is due. In response to such a shortfall, individuals are faced with many choices: some legal, some not; some sensible, some foolish. Consequently, the April filing deadline often marks the beginning of a trying period during which many taxpayers try to arrive at some arrangement with state and federal taxing authorities. If negotiations are successful, a payment schedule might result. If negotiations fail, the taxpayer may be the subject of tax liens -- and as is often the case, such a financial predicament indicates the likelihood that other creditors are losing patience and may take steps resulting in civil judgments. Frequently, the crush of income-tax liens and civil judgments lead to a petition seeking a discharge in bankruptcy.

Wall Street's registered representatives are faced with some unique employment, compliance, and regulatory issues when confronted by liens, civil judgments, and bankruptcy. As such, make sure to secure competent legal counsel when considering how to handle any potential non-payment of taxes or creditors. What you do and how you do it could have devastating career impact.  As to some of your disclosure obligations, let's briefly consider a few rules and regulations pertaining to your disclosure obligations pertaining to liens, judgments, and bankruptcies. Following that rulebook review, let's consider how FINRA charges and sanctions non-disclosure -- which, sadly, doesn't seem to be in a consistent manner. . . it comes off willy nilly. READ 

SEC Issues Historic Stay Of ALJ Initial Decisions

I have been in the securities industry since 1982, when I worked in the Legal Department of Smith Barney, Harris Upham & Company. For one of the few times in my legal career, I am astonished by the SEC's Order to stay all administrative proceedings on review from an ALJ's Initial Decision that are subject to 10Cir review. The  SEC's stay is a profoundly commendable step by the federal regulator; and also serves as a confirmation and vindication of my interpretation of BandimereREAD 

This morning I planned publish an article about a regulatory development but I just don't feel that it's okay to ignore the murder of 22 human beings and the wounding of 59 others last night in a terrorist bombing in Manchester, England.  At a concert. Targeting kids. Unspeakable. Disgusting. Pointless.

Yes, I know, we must get on with our lives in order to show the terrorists that they won't win. I wholeheartedly embrace that response. On the other hand, on 9/11, I walked some ten miles from near Ground Zero to my home. I saw it all that day -- which is why I know how important it is to retain our humanity in the face of such ugliness. As such, we need to pause. Even if only for a moment. READ 

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In both the SEC's and FINRA's "judicial" venues, the cards are stacked against you. At the SEC, you have your constitutional protections but they try to railroad you into an in-house court system. At FINRA, they not only have their own in-house court system but don't recognize your constitutional rights. Of course you have the option of employing counsel if you can afford the expense.

There is a need for regulation in the financial services industry but it must be meted out with an even hand. The form of justice to which the "Little Guy" is subjected is, often times, draconian and whittles away at the very fabric of what binds us all together. READ