Once again, this case illustrates that there is no consistent rationale to the FINRA penalties imposed on individuals. For example, in a  a broker that caused $100,000 in losses and costs to a retiree was not hit with any money penalty and got a three-month suspension. But in this case, an administrative assistant, who may not have realized that she was doing something improper, and did not cause any customer injury, was subject to a $5,000 fine and a six-month suspension. These are not…

Under the prior Administration, there were continued complaints that the private capital markets had become overly important in comparison with the public markets. No serious consideration was given as to how that trend could be reversed, or as to whether the SEC shared material responsibility. One egregious example of the SEC refusing to ask itself what role its regulations had played in the decline of the public capital markets was former SEC Chair Gensler's claim that a twenty-five year…

It is somewhat unusual for an enforcement action to be taken against the FinOP rather than the firm.  

Firms should give consideration as to how this expansion of operating hours will impact operations, accounting, and contractual terms. At what hour of the day do their books "close" for the day? What time of day is a Fedwire payment required to be received?