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Seminar  Seminar

Fundamentals of Broker-Dealer Regulation 2013


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This is a webcast of the live New York session.

Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

All times are E.D.T

Morning Session: 9:00 a.m. - 12:15 p.m. (E.D.T.)

9:00 Overview of Program; Who is a Broker-Dealer?
  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents
Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership
  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons
Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction
  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives
Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m. (E.D.T.)

1:15 The Customer Relationship
  • Suitability
  • Rules governing the customer account
  • Disclosure
Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)
  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges
Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams
  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program
John R. Hewitt, Chris Salter

5:00 Adjourn
Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute
PLI makes every effort to accredit its Live Webcasts. Please check the CLE Calculator above for CLE information specific to your state.

PLI's Live Webcasts are approved for MCLE credit (unless otherwise noted in the product description) in the following states/territories:  Alabama, Alaska, Arkansas, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois, Indiana1, Iowa*, Kansas*, Kentucky*, Louisiana, Maine*, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, New Hampshire*, New Jersey, New Mexico, Nevada, New York2, Ohio3, Oklahoma, Oregon*, Pennsylvania4, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia5, Virgin Islands, Washington, West Virginia, Wisconsin, and Wyoming*.

*PLI will apply for credit upon request.

Arizona: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

Arkansas and Oklahoma: Audio-only live webcasts are not approved for credit.
 

1Indiana: Considered a distance education course. There is a 6 credit limit per year.

2New York: Newly admitted attorneys may not take non-transitional course formats such as on-demand audio or video programs or live webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.

3Ohio: To confirm that the live webcast has been approved, please refer to the list of Ohio’s Approved Self Study Activities at http://www.sconet.state.oh.us. Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per biennial compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.

4 Pennsylvania: A live webcast may be viewed individually or in a group setting. Credit may be granted to an attorney who views a live webcast individually. There is a 4.0 credit limit per year for this type of viewing. A live webcast viewed in a group setting receives live participatory credit if the program is open to the public and advertised at least 30 days prior to the program. Live webcasts viewed in a group setting that do not advertise at least 30 days prior the program will be considered "in-house", and therefore denied credit.

5Virginia: All distance learning courses are to be done in an educational setting, free from distractions.


Running time and CLE credit hours are not necessarily the same. Please be aware that many states do not permit credit for luncheon and keynote speakers.

Note that some states limit the number of credit hours attorneys may claim for online CLE activities, and state rules vary with regard to whether online CLE activities qualify for participatory or self-study credits. For more information, refer to your state CLE website or call Customer Service at (800) 260-4PLI (4754) or email: info@pli.edu.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?
  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents
Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership
  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons
Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction
  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives
Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship
  • Suitability
  • Rules governing the customer account
  • Disclosure
Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)
  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges
Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams
  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program
John R. Hewitt, Chris Salter

5:00 Adjourn
Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute
New York City Seminar Location

PLI New York Center, 810 Seventh Avenue at 53rd Street (21st floor), New York, New York 10019. Message Center, program days only: (212) 824-5733.

New York City Hotel Accommodations

The New York Hilton & Towers1335 Avenue of the Americas, New York, NY 10019. 1 block from PLI Center. Reservations 1-800-HILTONS or, 1-877-NYC-HILT. Please mention that you are booking a room under the Practising Law Institute Corporate rate and the Client File # is 0495741. You can also make reservations online to access Practising Law Institute rates.

The Warwick New York Hotel, 65 West 54th Street New York, NY 10019. 1 block from PLI Center. Reservations 800-223-4099 or, hotel direct 212-247-2700. Please mention that you are booking a room under the Practising Law Institute Corporate rate. Reservations on line at www.warwickhotelny.com Click reservations in menu bar on left. Select desired dates. In 'Special Rates' drop down window select Corporate Rate. In 'Rate Code' enter PLIN. Click search and select desired room type and rate plan. Or, you may email reservation requests to: res.ny@warwickhotels.com

Sheraton New York Hotel & Towers, 811 7th Avenue, New York, NY 10019, 1-800-325-3535 or (212) 581-1000. When calling, please mention Practising Law Institute and mention SET#311155. You may also book online.

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the Pennsylvania Bar Institute's CLE Conference Center, Wanamaker Building, 10th floor, Philadelphia (Juniper St. entrance, between 13th & Broad Sts., opposite City Hall). You will have the opportunity to submit questions and will receive the printed Course Handbook.


Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

5:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute

Philadelphia Groupcast Location

Pennsylvania Bar Institute, The CLE Conference Center, Wanamaker Building, 10th floor, Suite 1010, Center City Philadelphia (Juniper St. entrance, between 13th & Broad Sts., opposite City Hall). (800) 932-4637.  Click here for directions.

Philadelphia Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:

Marriott Residence Inn

Ritz Carlton

Loews Philadelphia  

Philadelphia Marriott Downtown
Hilton Garden Inn

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the the Pennsylvania Bar Institute's Professional Development Conference Center, Heinz 57 Center, 339 Sixth Avenue, 7th Floor, Pittsburgh, Pennsylvania 15222-2517. You will have the opportunity to submit questions and will receive the printed Course Handbook.

Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

5:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute

Pittsburgh Groupcast Location

Pennsylvania Bar Institute, Professional Development Conference Center, 339 Sixth Avenue, Suite 760, Pittsburgh, Pennsylvania 15222-2517. (412) 802-2300. Click here for directions.

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Co-Sponsored by Massachusetts CLE

Attendees in Boston will be seeing the live broadcast from New York City at the conveniently located offices of Massachusetts CLE, 10 Winter Place, Boston, Massachusetts. Remote Location participants will receive all course materials.


Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

5:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute

Boston Remote Location

Massachusetts CLE, 10 Winter Place, Boston, Massachusetts 02100. (617) 350-7006.

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Co-Sponsored by New Jersey Institute for Continuing Legal Education

Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

5:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute

New Jersey Groupcast Location

New Jersey Institute for Continuing Legal Education, One Constitution Square, New Brunswick, NJ 08901-1520. 732-249-5100.

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 8:00 a.m. - 11:15 p.m.  (C.D.T.)

8:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

9:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

10:00 Networking Break

10:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

11:15 Networking Lunch

Afternoon Session: 12:15 p.m. - 4:00 p.m.  (C.D.T.)

12:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

1:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

2:30 Networking Break

2:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

4:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute
Alabama Groupcast Location

Cumberland School of Law, Samford University, 800 Lakeshore Drive, Birmingham, AL 35229

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the Pennsylvania Bar Institute, 5080 Ritter Rd., Mechanicsburg, PA 17055. You will have the opportunity to submit questions and will receive the printed Course Handbook.


Why you should attend

Major changes in broker-dealer regulation and the industry have come about as a result of the financial services crisis and the resulting regulatory reform. At the same time, FINRA’s overhaul of its rulebook as part of its Rulebook Consolidation process is almost complete. This program will provide attendees with a solid foundation in the regulatory regime applying to broker-dealers, including what to expect next regarding broker-dealer regulation. Attendees will learn how the Securities Exchange Act of 1934, FINRA rules and state securities laws interact in governing the brokerage industry.

Attendees will also learn about recent regulatory enforcement activity by the SEC, FINRA, and the States and about how broker-dealers are responding to these developments and the challenges ahead for the industry.

A distinguished faculty will offer insights into recent rulemaking that is having far-reaching impact on the day-to-day operations of firms.

What you will learn

  • Who are the regulators and how do they interact?
  • What is entailed with respect to the duty to supervise?
  • How are conflicts of interest resolved?
  • What is “suitability”?
  • Developments regarding broker-dealer and advisory services
  • What is the role of the chief compliance officer?
  • How do the SEC and FINRA conduct inspections?

Who should attend

Anyone entering the brokerage industry will benefit from a thorough grounding in the basic regulatory regime governing the industry as will anyone already working in the industry who would like a refresher.

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Morning Session: 9:00 a.m. - 12:15 p.m.

9:00 Overview of Program; Who is a Broker-Dealer?

  • The broker-dealer definition
  • Exceptions to the definition
  • Status of finders and placement agents

Robert L.D. Colby, Joanne C. Rutkowski

10:00 Broker-Dealer Registration and FINRA Membership

  • Registration as a broker-dealer: The Form BD
  • FINRA’s membership process
  • The membership agreement
  • Registration of Associated Persons

Clifford E. Kirsch, Allison Reid

11:00 Networking Break

11:15 Regulatory Jurisdiction

  • State regulation
  • SRO regulation
  • The interplay between the SEC, the SROs and the States
  • Current initiatives

Stephen Luparello, G. Philip Rutledge

12:15 Networking Lunch

Afternoon Session: 1:15 p.m. - 5:00 p.m.

1:15 The Customer Relationship

  • Suitability
  • Rules governing the customer account
  • Disclosure

Clifford E. Kirsch, Susan S. Krawczyk

2:15 Supervision and Compliance Programs (Legal Ethics)

  • Rules requiring supervision
  • The CLO/CCO as supervisor
  • Requirements regarding compliance reviews
  • Requirements regarding the design of a compliance program
  • Current supervisory challenges

Doria G. Bachenheimer, Duane L. Hughes, Clifford E. Kirsch

3:30 Networking Break

3:45 Financial Responsibility, Recordkeeping, and Exams

  • The Net Capital and Customer Protection Rules
  • Recordkeeping
  • The SEC and FINRA’s exam program

John R. Hewitt, Chris Salter

5:00 Adjourn

Chairperson(s)
Clifford E. Kirsch ~ Sutherland
Speaker(s)
Doria G. Bachenheimer ~ Managing Director, General Counsel, Regulatory Law, TIAA-CREF Financial Services
Robert L.D. Colby ~ Chief Legal Officer, FINRA
John R. Hewitt ~ McCarter & English, LLP
Duane L. Hughes ~ Managing Director, Morgan Stanley Wealth Management
Susan S. Krawczyk ~ Sutherland
Stephen Luparello ~ Wilmer Cutler Pickering Hale & Dorr LLP
Allison Reid ~ Associate Director, FINRA
Joanne C. Rutkowski ~ Branch Chief, Office of Chief Counsel, Division of Trading and Markets, U.S. Securities and Exchange Commission
G. Philip Rutledge ~ Bybel Rutledge LLP
Chris Salter ~ Allen & Overy
Program Attorney(s)
Lauren E. Nochta ~ Program Attorney, Practising Law Institute

Mechanicsburg Groupcast Location

Pennsylvania Bar Institute, 5080 Ritter Rd., Mechanicsburg PA 17055, (800) 932-4637.  Click here for directions.

Mechanicsburg Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:
 
Hampton Inn Harrisburg-West, 4950 Ritter Road, Mechanicsburg, Pennsylvania, USA 17055. Tel: 717-691-1300. Fax: 717-691-9692.

Homewood Suites by Hilton® Harrisburg-West Hershey Area, 5001 Ritter Road, Mechanicsburg, Pennsylvania, United States 17055. Tel: 1-717-697-4900. Fax: 1-717-697-9101.

PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.


Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Related Items

On-Demand  On-Demand Programs

Investment Management Institute 2013 Mar. 22, 2013
Hedge Funds 2012: Strategies and Structures for an Evolving Marketplace Sep. 19, 2012
Fundamentals of Investment Adviser Regulation 2012 Aug. 1, 2012
Fundamentals of Broker-Dealer Regulation 2012 Jul. 9, 2012

Handbook  Course Handbook Archive

Hedge Fund Management 2013  
Fundamentals of Investment Adviser Regulation 2013  
Fundamentals of Broker-Dealer Regulation 2013  
Investment Management Institute 2013 Barry P. Barbash, Willkie Farr & Gallagher LLP
Paul F. Roye, Capital Research and Management Company
 
Hedge Funds 2012: Strategies and Structures for an Evolving Marketplace W. Danforth Townley, Davis Polk & Wardwell LLP
 
Fundamentals of Investment Adviser Regulation 2012 Clifford E. Kirsch, Sutherland
 
Fundamentals of Broker-Dealer Regulation 2012 Clifford E. Kirsch, Sutherland
 
Institutional Investor Forum 2012 Nir Yarden, Haynes and Boone, LLP
 
Investment Management Institute 2012 Barry P. Barbash, Willkie Farr & Gallagher LLP
Paul F. Roye, Capital Research and Management Company
 
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All Contents Copyright © 1996-2013 Practising Law Institute. Continuing Legal Education since 1933.