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Communications and Compliance: Finding the Right Balance

SKU: FR2200
Total Credits
  • Online Access
  • Smartphone
  • iPad/iPod/Tablets
  • CDs/DVDs


This CLE program will address what compliance and legal professionals need to know about upcoming and proposed changes to the broker dealer communications rules including amendments to the filing requirements, potential performance standards, and new disclosure approaches. Panelists will also discuss guidance in development with respect to social media, mobile devices and digital communications. The panel will also share considerations arising from how the industry has implemented JOBS Act rule changes in their communications.

After attending this session, you will be able to:

  • Understand the status of proposed changes to FINRA’s filing requirements;
  • Discuss FINRA’s review of websites dedicated to the offer of private placements and crowdfunding;
  • Consider the development of additional guidance for digital communications, social media, and mobile devices;
  • Evaluate proposals regarding disclosure and individualized performance communications; and
  • Apply FINRA’s new rule requiring the inclusion of a link to BrokerCheck on websites.

FINRA® is a registered trademark of the Financial Industry Regulatory Authority, Inc.

Lecturer Bios

Amy C. Sochard

Amy C. Sochard is the Senior Director in FINRA’s Advertising Regulation Department. The department protects investors by ensuring broker-dealer members of FINRA use advertisements and other sales communications that are fair, balanced and not misleading. Ms. Sochard leads the department’s investigative and targeted examination activities. She also serves as liaison to other FINRA departments involved in examinations, including the departments of Enforcement and Member Regulation. In addition, Ms. Sochard oversees staff dedicated to the routine review of advertisements and other sales communications filed with the department by broker-dealers. Ms. Sochard assists in the development of rules and interpretations for communications with the public and social media, and she routinely speaks at industry events on these topics. Prior to joining FINRA’s predecessor (NASD), Ms. Sochard worked with a real estate syndication firm in Washington, DC. She received a bachelor’s degree with distinction in English from the University of Virginia and studied poetry writing at Columbia University.

Alexander C. Gavis, Esq.

Alexander C. Gavis is Senior Vice President & Deputy General Counsel in the Corporate Legal Department of FMR LLC, the parent company of Fidelity Investments, one of the largest brokerage and mutual fund companies in the United States and the leading provider of workplace retirement savings plans. He manages a team of attorneys and professionals and is responsible for providing legal services to the firm's retail brokerage, college savings, stock plan and workplace retirement businesses. He also oversees and manages legal services for Fidelity's businesses involved in electronic and mobile commerce, start-up innovation, and social media. Mr. Gavis also oversees legal advice on all of Fidelity’s national advertising and marketing initiatives. He serves as chair of the firm’s Social Media and E-Communications Legal Practice Group. Prior to joining Fidelity in 1997, Mr. Gavis served as Assistant Counsel at the Investment Company Institute and as Senior Counsel in the Office of General Counsel at the U.S. Securities and Exchange Commission, both in Washington, DC. He also served as a judicial law clerk for The Honorable William T. Allen, Chancellor of the Court of Chancery for the State of Delaware. He has worked in investment banking in New York at Salomon Brothers Inc, handling mergers and acquisitions. Mr. Gavis received his J.D., cum laude, from the University of Pennsylvania Law School, where he served as Editor-in-Chief of the University of Pennsylvania Law Review, and his bachelor’s degree, with High Honors and Phi Beta Kappa, from Swarthmore College. Mr. Gavis served as Chair of FINRA’s Social Media Task Force and on its Membership Committee, and he is an adjunct professor at Suffolk University Law School and the Stanford Design School. He has served as President and a board member of the Wellesley Free Library Foundation.

Erica A. Green

Erica A. Green is the Vice President and General Counsel of FOLIOfn Investments, Inc. Ms. Green has extensive experience in the financial services industry with small and large financial services firms, primarily serving as inside and outside legal counsel relating to all aspects of broker-dealer regulation. Ms. Green currently oversees the team at FOLIOfn Investments, Inc. (Folio) that is charged with addressing the legal and compliance issues of the firm, including general corporate matters and compliance with the federal and state securities laws, rules and regulations as well as those of FINRA and the SEC. Folio, a self-clearing firm, offers online self-directed, brokerage services to retail investors, investment advisors and other broker-dealers, including facilitating transactions in publicly-traded equity securities, registered debt and private placements. Folio’s websites (including the secondary trading platforms of two peer-to-peer lending platforms), advertising and other sales materials of Folio fall within the team’s purview for review and compliance with the firm’s advertising policies, and FINRA and SEC advertising rules. Prior to joining Folio in November 2013, she was Vice President, Associate General Counsel with Goldman, Sachs & Co., where she focused on the electronic trading-related activities of the firm, including its affiliate Goldman Sachs Execution & Clearing, L.P. In that role, as the primary legal contact, she worked with marketing, business and compliance personnel to develop marketing materials relating to the Goldman Sachs Electronic Trading products. Before joining Goldman, Sachs & Co., Ms. Green spent over 6 years at Wilmer Cutler Pickering Hale and Dorr LLP advising broker-dealers on corporate and SEC and FINRA regulatory matters and investment management clients with respect to trading agreements and transactions.

Thomas A. Pappas

Thomas A. Pappas is Vice President of the FINRA Advertising Regulation Department, which regulates the advertisements, sales literature and correspondence used by FINRA member firms. His responsibilities include rule development, management of the filing and surveillance programs and related enforcement activities. He served in the same role at NASD before its 2007 consolidation with NYSE Member Regulation, which resulted in the formation of FINRA. He was previously registered with Davenport & Company LLC. He received a bachelor’s degree from The University of Richmond and an MBA from Virginia Commonwealth University.

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