Posts Tagged:reasonable basis suitability

Finra Reflects on the SRO Model

Finra Executive Vice President, Thomas M. Selman, spoke at the Investment Program Association Fall Conference on November 15, 2012 and made some interesting comments.  (IPAFC)  I have extracted some of the better parts below. Here’s another pitch for Finra (and not the SEC) to regulate Investment Advisors: Despite the longstanding faith in the SRO model,…

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Finra EVP Susan Axelrod on Complex Products and Suitability

Speaking at a PLI Seminar on Broker-Dealer Regulation and Enforcement on October 24, 2012, Finra EVP Susan F. Axelrod had some interesting comments on Complex Investments, the new Suitability Rule 2111, and Know Your Customer Rule 2090.  (Axelrod)  You can also see our previous coverage on Complex Products here.  Below are some extracts. Finra has…

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Finra Sanctions David Lerner Associates $12 million for Apple REIT Ten Sales

A Finra news release yesterday reported the regulator fined David Lerner Associates $12 million for sales of Apple REIT 10.  (Finra)  The funds will go towards restitution for the Apple REIT 10 customers.  The release quoted Brad Bennett, Executive Vice President and Chief of Enforcement: David Lerner and his firm targeted unsophisticated and elderly customers,…

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Complex Products Speech by Finra Chairman and CEO Richard G. Ketchum

Finra Chairman and CEO Richard G. Ketchum delivered some enlightening remarks at the SIFMA Complex Products Forum on September 27, 2012.  (Speech).  The speech is well worth the read.  There are many items of note in Ketchum’s remarks.  Some are highlighted below (with useful links at the end): An attempt at a definition of complex…

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