
Alan J. Foxman
Managing DirectorAlan J. Foxman is a managing director at Foreside Financial Group.

Alan J. Foxman is a managing director at Foreside Financial Group.
Rule 11870 permits member firms to use them rather than obtaining an affirmative authorization from the client — in certain situations.
In most cases, assume that your "outside business" is not affiliated with your current employer.
Does a poor stock pick, for instance, constitute a sales practice violation?
Maybe not, says FINRA — but if you’re IM’ing, using slides during the virtual meeting, or recording it, probably yes.
While FINRA rules spell out what brokers generally need to determine a client's financial situtation, there can be gray areas, an expert says.
Regulators will conduct surveys and sweep exams to assess how your firm’s BCP handled — or didn’t — the COVID-19 pandemic
Yes, they’ll be going up in September — but not as much as you may have heard.
Despite recent upheaval, some clients will still be shocked their portfolios have shown declines.
My broker-dealer warned that since it’s a forgivable loan it could be seen as a compromise with creditors.
That would be a big “no,” in most cases, according to FINRA, but gives rise to another question…
Make sure not to confuse it with the SEC’s self-reporting program.
The SEC says broker-dealers may treat investment advisors as if they were subject to the AML Rule — under certain conditions.
Not a great idea, says Alan Foxman, but if you’re determined, there may be a way.
Deciding what does or doesn’t constitute a “material change” can be a tough call.
Due to a 2010 FINRA rule change the answer is — with difficulty.
At this stage it's not an actual data breach, but it could become one.
There are red flags that may be pointing to elder fraud in a client account.
FINRA Rule 3210 typically requires permission for brokerage accounts.
An advisor was terminated after accepting money from a brother, who was also a client. Is such a loan allowed?
Having ‘fessed up to improper 12b-1 fee disclosures, dually registered advisors might still be excluded by FINRA.