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3
Jan
2022
FINRA Strongly Suggests Actions on Business Continuity Plans
Posted On January 3, 2022  By Morris Simkin  And has No Comment

FINRA Rule 4370 requires member firms to create, maintain and annually review and, if necessary, update a business continuity plan (BCP) relating to an emergency or significant business disruption. FINRA recently published Regulatory Notice 21-44 (RN 21-44) setting forth its observations after reviewing firm BCPs resulting […]

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3
Mar
2020
Once, This Issue Was Clear As Mud. Now, It’s As Transparent As Pea Soup
Posted On March 3, 2020  By Morris Simkin  And has No Comment

ISSUE: WHEN CAN YOU SOLICIT IN A PRIVATE PLACEMENT? SEC Interpretations. SEC Rule 506(c) allows “general solicitations” — advertising, in private placements under Regulation D where all the purchasers are “accredited investors,” as defined in Rule 501. Private placements relying on Rule 506(b) can include up […]

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