May 24, 2019
Howard Diamond Quoted
The issue came up, only half facetiously, at Finra’s annual conference in Washington last week during a wide-ranging discussion of what broker-dealers can do to fend off regulatory criticism and enforcement action for hiring rogue brokers and failing to supervise bad behavior.
“The cold hard fact is that—for purposes of an advisor’s Form U4 disclosure obligations—these events stay with the individual like a bad haircut that never seems to grow out,” Howard Diamond, general counsel of headhunting firm Diamond Consultants wrote in a 2016 article advocating disclosure of “even the most mundane or long-forgotten youthful indiscretions” in the ever-growing “hypervigilant compliance environment.”
