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Edward Scarillo Jr.

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Articles by Edward Scarillo Jr.

You Made the List: SEC’s Spring Agenda Would Impact Broker-Dealers | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
The SEC’s Office of Information and Regulatory Affairs recently released the Spring 2023 Unified Agenda of Regulatory and Deregulatory Actions (the Agenda). The word salad of a title hints at the fact the SEC is considering a plethora of new rules. Indeed, many of the new rules, if finalized, would impact broker-dealers (BD) and investment advisers (IA).
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New Year’s Priorities: FINRA Releases its 2023 Report on its Examination and Risk Monitoring Program | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
Yes, (somehow) it is that time of year again. FINRA recently released its 2023 Report on its Examination and Risk Monitoring Program (the “Report”). As is typical (and this blog has well-covered), it contains a mix of old and new priorities.
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Having a Senior Moment: Recent Legislation and Rules to Protect Seniors from Financial Exploitation | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
In recent years there has been a spate of legislation and rules passed to protect senior investors. Similarly, observers of FINRA’s and the SEC’s annual priorities will, of course, have noticed both bodies’ inclusion of elder protection. The trend appears unmistakable: firms and registered individuals should continue to expect regulatory bodies and lawmakers to beef up senior protection.
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Exam Time: FINRA Releases its 2022 Report on its Examination and Risk Monitoring Program | JD Supra

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By Sandra Dawn Grannum, Edward Scarillo Jr.
| JD Supra
A common phrase to abide by in the New Year is “out with the old, in with the new.” FINRA’s 2022 Report on its Examination and Risk Monitoring Program (the “Report”), however, contains a combination of old and new priorities. We previously previewed the Report. Old priorities, once again included, are: Anti-Money Laundering, Reg BI and Form CRS, and cybersecurity.
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Brace for Impact: It’s Going to be (Another) Busy Year for FINRA | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
F. Scott Fitzgerald said “There are only the pursued, the pursuing, the busy, and the tired.” FINRA may be all of these in 2022, as FINRA CEO Robert Cook announced FINRA’s laundry list of priorities during a SIFMA Q&A last week. Below are some of the highlights from his Q&A. Exam Time: Annual Exam and Risk Monitoring Findings While Mr. Cook advised the “ink isn’t dry” on the 2022 priorities, he suggested broker-dealers can expect more of the same, with some new additions.
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By Edward Scarillo Jr.
| JD Supra
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Risky Business: SEC Risk Alert Highlights Broker-Dealers’ Anti-Money Laundering Miscues and Encourages Firms to Beef Up Protection | JD Supra

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By Sandra Dawn Grannum, James G. Lundy, Edward Scarillo Jr.
| JD Supra
Ben Franklin once said “by failing to prepare, you prepare to fail.” Based on the SEC’s latest risk alert concerning broker-dealers’ anti-money laundering (“AML”) compliance (or lack thereof), some firms would be well served to heed Mr. Franklin’s advice. The SEC specifically seeks to examine broker-dealers’ compliance with the various regulations and laws governing firms’ AML obligations.
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Have No Fear, Reg BI Is Finally Here | JD Supra

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By Sandra Dawn Grannum, Edward Scarillo Jr.
| JD Supra
All things come to those who wait … even Regulation Best Interest (colloquially known as Reg BI). In what now feels like a lifetime since the Securities and Exchange Commission (SEC) adopted it (believe it or not, it was only adopted on June 5, 2019), Reg BI has now passed its compliance date of June 30, 2020. This article aims to provide a brief overview of Reg BI and decipher its implications for brokers and broker-dealers.
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States Enact Good Samaritan Broker Laws | JD Supra

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By Sandra Dawn Grannum, Edward Scarillo Jr., Nicole Wixted
| JD Supra
On January 22, 2016, the members of the North American Securities Administrators Association (NASAA) released the Senior Model Act. It was developed and approved to serve as a model statute for states to adopt to target financial exploitation of seniors and to shield from liability brokers and brokerage firms who acted to assist those seniors. The Senior Model Act comports with a multitude of legislation and regulatory protection for seniors.
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Wait Just a Minute: FINRA Loosens the Screws on Proposed Expungement Restrictions | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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Further Protection for Good Samaritan Brokers: States and FINRA Continue the Push to Protect Senior Investors by Protecting Brokers Who Do the Right Thing | Drinker Biddle & Reath LLP - JDSupra

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By Sandra Dawn Grannum, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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Reg BI Information Overload: The Countdown to June 2020 Continues with Planned Reg BI Stress Tests, Checklists and FAQS Courtesy of FINRA and the SEC | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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Waive or Pay: FINRA Reaches Final Settlements in Its Mutual Fund Waiver Initiative | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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An Imperfect Storm(s): FINRA Bars Compliance Personnel for Falsifying Branch Audit Data | JD Supra

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By Sandra Dawn Grannum, Jamie Helman, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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Recent State Fiduciary Duty Developments: Updates from Massachusetts, New Jersey, Illinois and the CFP Board. | JD Supra

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By Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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House Looks to Put the Brakes on Reg BI | JD Supra

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By Jamie Helman, Edward Scarillo Jr.
| JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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