Comment on FINRA Regulatory Notice 25-07: Modernizing FINRA Rules, Guidance, and Processes for the Organization and Operation of Member Workplaces
FINRA’s rule modernization effort was built around large-firm assumptions. TOBIN spelled out what that costs boutique firms: inspections triggered by routine marketing approvals, enforcement investigations with no defined endpoint, and informal guidance enforced retroactively. She pushed for codified rules, shorter exam cycles, and a framework that treats small firms as professionals, not suspects.
The Hidden Risks of Newer Boards—and Why Guardrails Matter
Last month, I joined a panel at the Private Company Governance Summit in Washington, D.C., focused on a critical but often-overlooked issue: conflicts of interest on newer private company boards. The conversation, moderated by Bill Hayes and joined by Tom Sween and Jim McHugh, sparked a level of engagement that confirmed what I’ve long believed: […]
Comment on FINRA Regulatory Notice 25-04: Broad Review to Modernize Rules
A sweeping comment covering six issues at once. TOBIN argued for updating the $100 gift limit, eliminating redundant complaint filings, using AI to standardize advertising interpretations, permitting financial projections for accredited investors, and fixing what she described as enforcement inconsistency that falls harder on women and minority-owned firms.
Top Five Trends in (Smaller) M&A
Or, stated another way…. Private Equity is Hungry in 2025: What SMB Founders Need to Know How often have you seen a newsletter about the “TOP TRENDS IN M&A” and started reading with excitement, only to find that the author’s content is about large M&A deals and offers little value to founders and owners of […]
Comment on FINRA Regulatory Notice 25-05: Outside Business Activities and Private Securities Transactions
TOBIN opposed a proposal that would require her firm to supervise representatives’ work at unaffiliated investment advisers, even though that work is already regulated by the SEC or state authorities. Her position: stacking redundant supervision on boutique firms doesn’t protect anyone. It just slows growth and burns compliance capacity on activities that pose no genuine investor risk.
Chaperoning Broker-Dealer Engagements –
How Do They Work?
If you are a foreign broker dealer – that is, a broker-dealer NOT registered with the U.S. Securities & Exchange Commission (SEC) – you can still conduct securities business in the United States. Fortunately, you are not required to become a licensed U.S. broker dealer. Instead, you can partner with TOBIN and be “chaperoned” under […]
Common Pitfalls in M&A – and How to Avoid Them
It’s an understatement to say that delving into a merger with, or the sale or purchase of, a company is a momentous business move. It makes sense that the M&A journey can be fraught with pitfalls. These are the hazards that I, with my decades of M&A experience, find to be quite common and that […]
Mergers and Acquisitions: Key Steps and Strategies for Success
Growth through M&A is never accidental. It’s the result of deliberate strategic alignment, exhaustive planning and experienced execution. At TOBIN, we understand that pursuing a merger or acquisition isn’t about volume or vanity—it’s about precision, insight and value creation. Understanding the Difference: Merger vs. Acquisition A merger typically joins two companies of comparable size and […]
Maximizing Value: Why TOBIN is the Right Investment Banker for Your Small-Company Business Sale
Embarking on the journey of selling your business is a monumental decision, one that necessitates an advisor who not only comprehends the intricacies of mergers and acquisitions (M&A) but also tailors its approach to the unique aspects of your company. For sellers with revenues of $25 million or less, who may be feeling a bit […]
Know the Difference—Choosing between 506(b) and 506(c)
KNOW THE DIFFERENCE – EDUCATE YOURSELF! Your Reg D Private Placement Offering: Choosing between 506(b) and 506(c) for your Registration Exemption Last month I wrote to you about your registration exemptions when you sell a Reg D private placement. Generally, the exemptions that we choose from are 506(b) or 506(c): 506(b) – Old fashioned, been-around-forever […]