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Joshua is co-editor and a frequent contributor to Securities Compliance Sentinel, a blog that provides analysis of cutting-edge securities industry issues.

Joshua is co-editor and a frequent contributor to In the Weeds, a blog that aims to help keep today’s cannabis entrepreneur well informed.

Scroll down to see Joshua's most recent posts.

Recent Blog Posts

  • So Who Wants To Lie On Their U-4   The SEC recently upheld a statutory disqualification that FINRA imposed where the representative filed a false U-4 and falsely answered compliance questionnaires. It appears as though the registered representative failed to disclose tax liens and a bankruptcy on his U-4. So is statutory disqualification the proper punishment for this misdeed. According to FINRA and the SEC, the answer is a resounding yes and, unfortunately for the registered representative, this makes sense. After all, the U-4 is the lynchpin of what must... More
  • So The SEC Is Now Focused On Retail Investors The SEC recently announced an enforcement initiative that will target retail investor harm. The agency’s task force will use data analytics to find widespread problems regarding fee disclosures and unsuitable investment recommendations. In addition to data analytics, the SEC will rely upon tips, complaints and referrals that come into the SEC. This heightened analysis of the retail investor market should be a wake-up call to firms who service the retail investor space. There are a few questions that you should be... More
  • FINRA Changes To Arbitration Procedure FINRA is considering a number of changes to its arbitration procedure.  For a good discussion on the subject, see this article.... More
  • So You Think You Have No Cybersecurity Issues Recent exams have shown that cybersecurity weaknesses are a real issue for the industry.  This article from the Investment News provides the detail.    ... More
  • Cyber-Security and the SEC Alert   For a nice discussion on the SEC’s cyber-security alert, please see this link.... More
  • Cybersecurity — What are you doing The SEC recently issued an alert for investment advisors regarding cybersecurity.  Here is a link to a story on the alert.  Are you doing enough to fight this risk?  If you do not have an answer, then the answer is probably no.    ... More
  • Rogue Brokers Beware   FINRA is ever-increasing its focus on rogue brokers.  For the latest on this issue, check out this recent post.... More
  • FINRA Notice to Members; Enhanced Confirmation Disclosures FINRA has recently issued a notice to members regarding to the enhancement of confirmation disclosures.  Here is a link to that notice.    ... More
  • Ransomware; don’t be held hostage Ransomware has become an ever increasing problem as we become more technology dependent. To learn more about it and how to avoid it, read this blog.... More
  • The Tale of the Recidivist Broker The CEO of FINRA recently announced that FINRA plans to provide firms with additional resources to deal with recidivist brokers. So what does this mean? For years, FINRA’s exam priorities have focused on, among other things, brokers who are repeat violators of FINRA rules. FINRA has made this a priority as a way to weed out brokers who do not deserve to be in the industry because they are likely causing more harm than good. FINRA is effectively asking the firms to... More
  • Jennifer Benda Speaks About IRC Section 280E And IRS Enforcement On May 10, 2017, our partner, Jennifer Benda, will be speaking at a Colorado Bar Association event in Denver. She will be presenting an overview of federal taxation of marijuana, as well as a discussion of IRS enforcement issues for marijuana companies. For more information, call 303-860-1115, X727 ... More
  • Who Wants The 411 On 420 If you want to learn more about what states permit the medical or adult use of cannabis, check out our national survey on cannabis law which is updated on a weekly basis. Here is the link. Happy 420.Copyright: arinabodorina / 123RF Stock Photo... More
  • New York Opening Up To Expand Access To Medical Cannabis New York has recently taken steps to increase access to medical cannabis. Our colleague, Eric Bixler, recently blogged on this issue. Check the blog out here.... More
  • Chicago Tribune’s Review Of The Cannabis Law Practice The Chicago Tribune recently ran an article regarding the practice of cannabis law, and quoted our partner, Bill Bogot; check out the article here.... More
  • Does This Give Rise To A Happy 420 Over the years, federal spending for the prosecution of medical marijuana businesses has been curtailed by the Rohrabacher-Farr Amendment to the spending bills. Now that Farr is retired, the question remained whether there would be further support for such a bipartisan effort. It turns out that Rohrabacher has found some new bipartisan support for the effort. Rohrabacher and Earl Blumenauer from Oregon have proposed to include similar limiting language to the 2018 spending bill. If such limiting language... More