Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


FINRA Proposed Rule Amendments - Discovery Guide and Membership Application

Posted on July 30, 2018 at 7:35 AM

Regulatory Notice 18-22

FINRA Requests Comment on Proposed Amendments to Its Discovery Guide to Require Production of Insurance Information in Arbitration

Comment Period Expires: September 24, 2018


FINRA is requesting comment on proposed amendments to the Discovery Guide’s (Guide) Firm/Associated Persons Document Production List (Firm/ Associated Persons List) to require firms and associated persons, upon request, to produce documents concerning third-par...

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NY DFS to Issue a Final Regulation Requiring Credit Reporting Agencies to Comply with New York's First-in-the-Nation Cybersecurity Regulation

Posted on June 26, 2018 at 8:00 AM

New York's Department of Financial Services ("DFS") has issued a final regulation to protect New Yorkers from the threat of data breaches at credit reporting agencies. DFS, in response to the data breach at Equifax issued New York's first-in-the-nation cybersecurity regulation, to safeguard New York's markets, consumers and sensitive information from cyberattacks. The Equifax breach exposed the personal private data of millions of New Yorkers. DFS's oversight of credit reporting agencies will...

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SEC Charges 13 Private Fund Advisers for Repeated Filing Failures

Posted on June 1, 2018 at 2:10 PM

The SEC announced settlements with 13 registered investment advisers who repeatedly failed to provide required information that the agency uses to monitor risk. 

According to the SEC’s orders, the advisers:

  • failed to file annual reports on Form PF informing the agency about the private funds they advise, including the amount of assets under management, fund strategy, performance, and use of borrowed money and derivatives;
  • were delinquent in their filings ov...
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Altaba, Formerly Known as Yahoo!, Charged With Failing to Disclose Massive Cybersecurity Breach; Agrees To Pay $35 Million

Posted on April 24, 2018 at 1:40 PM

The SEC announced that the entity formerly known as Yahoo! Inc. agreed to pay a $35 million penalty to settle charges that it misled investors by failing to disclose one of the world’s largest data breaches in which hackers stole personal data relating to hundreds of millions of user accounts.

Per the SEC’s order:

• In December 2014 intrusion, Yahoo’s information security team learned that Russian hackers had stolen information on user accounts.


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SEC Obtains Bars and Suspensions Against Individuals and Accounting Firm in Shell Factory Scheme

Posted on February 20, 2018 at 10:50 AM

The SEC charged three Israeli residents, a Washington, D.C. attorney, and an Israeli auditor and his Maryland-based accounting firm for their roles in a fraudulent scheme in the creation of numerous public shell companies. The settlement requires the three Israeli residents to be subject to penny stock bars and the attorney and auditor to be prohibited from appearing and practicing before the Commission.

According to a complaint filed by the SEC:

• The defendants created at...

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FINRA Files Rule Changes to Registered Rep Exams

Posted on February 11, 2018 at 6:00 PM

Proposed Rule Change to Revise the Investment Banking Representative (Series 79) Examination

FINRA filed a rule change with the SEC revisions to the content outline and selection specifications for the Investment Banking Representative (Series 79) examination as part of the restructuring of the representative-level examination program. The proposed revisions also update the material to reflect changes to the laws, rules and regulations covered by the examination and to incorporate the f...

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SEC Requests Comments on Form PF

Posted on January 16, 2018 at 7:15 PM

The SEC is requesting comment on the Form PF ("Reporting Form for Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors"). The form is required for all private fund advisers with at least $150 million in private assets under management and intended to aid the Financial Stability Oversight Council in monitoring systemic risk, and in allocating its regulatory tools for nonbank financial companies. The attached presentation sets out more inform...

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FORM ADV Changes - Summary

Posted on January 12, 2018 at 9:50 AM

I came across the following handy checklist published by the Investment Advisers Association that should be considered by investment advisers when they need to update their Form ADV.

As a reminder, highlights of the amendments to Form ADV include the following:

 Umbrella Registration for Private Fund Managers

 Separately Managed Accounts

 Other: The revised Form also now requires new or additional information regarding (among others):


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FINRA Fines J.P. Morgan Securities, LLC $1.25 Million for Failing to Appropriately Fingerprint or Screen Its Employees

Posted on November 27, 2017 at 7:30 AM

FINRA fined J.P. Morgan Securities, LLC $1.25 million for failing to conduct timely or adequate background checks on approximately 8,600, or 95 percent, of its non-registered associated persons from January 2009 through May 2017. Broker-dealers must fingerprint certain associated persons working in a non-registered capacity who may present a risk to customers based on their positions. This is done to help firms identify if a person has been convicted of crimes that would disqualify them from ...

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Broker Fined for Sharing Commissions with an Unregistered Person

Posted on November 15, 2017 at 8:05 PM

I saw this case discussed in Financialish.com and thought it was worth highlighting here.

In sum, Roy Woehrman, a California broker with LPL Financial, agreed to pay a $12.5K fine to settle FINRA charges that he shared commissions with an unregistered person for referrals paid from January 2013 to June 2014. Woehrman and the individual entered into a Referral/Lead Marketing Agreement under which the unregistered would refer individuals interested in purchasing alternative investments to...

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