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
- 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
- Rulemaking Through Enforcement; What’s Next? FINRA has rulemaking authority. Nevertheless, the trend would appear to be that FINRA is making its rules through the enforcement process. Read this blog for insightful thoughts on this issue.... More
- The Supreme Court Limits The SEC’s Ability To Seek Disgorgement The Supreme Court recently ruled that a five year statute of limitations applies to when the SEC seeks disgorgement. To learn more, read this alert. ... More
- What Are You Doing About Outside Business Disclosures? FINRA is currently reviewing its rules regarding outside business activities and private securities transactions. From time to time, FINRA reviews its rules and application of those rules to see if anything needs to be tweaked. Is there any significance to FINRA looking at these particular rules? From my experience, some bad brokers have used the outside business activity disclosure process as the tool to cover their tracks while engaging in activity that the firm would otherwise want to know about. In... More
- So You Want To Change Firms — Part II So you really want to change firms. Do you have a restrictive covenant or a non-compete? If so, your transition may be a little more complicated. To learn what restrictions may apply to you, check out our 50-state survey on restrictive covenants. ... 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