Compliance Guidance
- Initial and ongoing SEC or State registration filings, including disclosure documents such as:
- Form ADV Part 1
- Form ADV Part 2 (Brochure)
- Brochure Supplements
- Form ADV Part 3 (Relationship Summary/ Form CRS)
- Assistance with preparation or updates of U4 and U5 forms for representatives
- Assistance with IARD and CRD entitlement and administration
- Advice on compliance and supervisory procedures
- Compliance Manual and Code of Ethics, custom drafted for your business
- Drafting and updating Client Agreements
- Forms and checklists
- Assistance with business continuity planning
- Ongoing compliance guidance and support
Training And Continuing Education
FINRA requires broker-dealers to establish a formal Continuing Education training program to keep registered personnel current on professional and product-related subjects. Firms must administer their Firm Element Continuing Education Programs in accordance with their annual Needs Analysis and Written Training Plan, and must maintain records documenting the content and completion of the program.
Investment advisory firms are not subject to the same requirements (although as of 2024, eighteen states plus the U.S. Virgin Islands require investment advisor representatives to complete continuing education requirements, and representatives who are licensed to sell insurance, or who have earned certain designations (like Certified Financial Planners®) need to fulfill CE requirements each year).
Dana and Frank are engaging, experienced, knowledgeable speakers who provide education and training for investment advisor and broker-dealer compliance personnel, supervisors and representatives, including:
- Annual compliance meetings
- Compliance training on specific topics
- Firm element CE
Topics include:
- Anti-Money Laundering (AML)
- New Supervisor Training
- Advertising And Sales Literature Rules And Concepts
- Suitability Training For Representatives
- Fiduciary Duty Training For Representatives
- U4 Disclosures And Reporting
- Hot Topics — based on FINRA Priorities, SEC Priorities, recent enforcement actions
Litigation Services
Frank represents parties in litigation and FINRA arbitrations.
Litigation Management
When a broker-dealer or investment advisor does not have in-house counsel, or where in-house counsel does not have the time or desire to manage litigation, Frank can help the firm engage the best outside litigation counsel and manage them more efficiently and effectively.
Frank has decades of experience as a litigator, including significant time spent as in-house counsel in charge of litigation. He has broad and deep experience in litigation matters. He develops a global picture of our clients’ business and get to know the people, so he understands the issues they are facing and can anticipate their concerns and needs. He provides valuable insight to assist clients in developing and executing an overall litigation strategy, as well as anticipating possible issues so that the company can take steps to minimize its litigation risk going forward.
Frank works with outside litigation counsel to develop a budget for each matter, and review the invoices to ensure the charges are appropriate. He serves as liaison between firm staff and outside counsel on discovery, which makes the document- and information-gathering process more efficient for the firm’s staff and more reliable for outside counsel. He reviews outside counsel’s draft pleadings and other papers before they are filed, and provide substantive, useful guidance and feedback to outside counsel on pleadings, papers and presentations, as well as on litigation strategy and tactics. He ensures that the company’s positions in each litigation are aligned with the company’s overall business, legal and litigation strategy.