Chairman Kanjorski, Ranking Member Garrett and Members of the Subcommittee: I am Steve Luparello and I currently serve as Interim CEO of the Financial Industry Regulatory Authority, or FINRA. On behalf of FINRA, I would like to thank you for the opportunity to testify today.
(a) All capital acquisition brokers are subject to paragraphs (a)(1) through (a)(6), (b)(1), (b)(4), (b)(5), (b)(7), (e) and (f) of FINRA Rule 3110, and Supplementary Materials .01 through .03, .06 through .09, and .11 following FINRA Rule 3110.
(b) A capital acquisition broker must permit the examination and inspection of its premises, systems, platforms, and records by representatives of FINRA
<p>Clarification of application of OATS rules to customer allocations of executions.</p>
<p>A member firm may pay continuing commissions to a former registered representative who is no longer in the securities business provided the conditions of NASD IM-2420-2 are satisfied, and further, that such payments are made in compliance with SEC "no-action" letters addressing the permissibility of those payments under Section 15(a) of the Securities Exchange Act of 1934.</p>
James Gonedes served two combat tours in Iraq as a Marine. While there, he formed many enduring bonds and friendships, including with fellow Marine Clayton Cohn. So when Clayton started working as an investment adviser in Chicago after their discharge, James gladly invested in his hedge fund business. He eventually gave Cohn almost $400,000—money James had inherited from his late father.
(a) Definitions
(1) For purposes of this Rule, the term “Specified Adult” shall mean: (A) a natural person age 65 and older; or (B) a natural person age 18 and older who the member reasonably believes has a mental or physical impairment that renders the individual unable to protect his or her own interests.
(2) For purposes of this Rule, the term “Account” shall mean any account of a member for
FINRA Enforcement works tirelessly on the front lines of investor protection, and this tremendous undertaking demands steadfast leadership. On this episode of FINRA Unscripted, we are reintroduced to Bill St. Louis, FINRA's new Executive Vice President and Head of Enforcement, to learn more about what's on the horizon for Enforcement in the new year.
FINRA’s Board of Governors met on September 13-14 in Philadelphia. In addition to continuing discussions around FINRA’s Regulatory Operations, the Board reaffirmed FINRA’s Financial Guiding Principles.
If you plan to move after the military, keep these points in mind when making your housing decisions.
GUIDANCE
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Regulatory
Senior Management
Financial and Operational Principals (FINOPs)
SEC Rule 15c3-1 (Net Capital Rule)
SEC Rule 15c3-3 (Customer Protection Rule)
SEC Rule 17a-5 (Reports to Be Made by Certain Brokers and Dealers)
Executive Summary
NASD is issuing this Notice to