But why is it that firms like Hudson always wind up with the same issue? Why do FINRA members try to copy other's WSPs or wind up filling pages with cut and pastes from FINRA's website or other sources--and, admittedly, the result isn't exactly pretty to look at or often tailored for the member firm?  You read your firm's WSPs within the last year? You even know where the WSP are in your firm? Yeah, I didn't think so.  This isn't regulation. This is going through the motions.

I read the lecture from FINRA about things not being cross-referenced and a lack of guidance to employees.  I mean, geez, we all know how very, very helpful cross-referencing is and that employees daily (hell, hourly) use the WSPs to ensure that they are always doing the correct thing (okay, you got me again -- more dripping sarcasm).  And, for extra measure--you know, that one last unnecessary punch from the bully--we're told that because the firm didn't have the AMLs FINRA wanted ,that its poor employees were left to figure out how to make sure the company's market making was AML compliant. Talk about loading up that last punch.

Look, the problem here is two-fold. One is the fiction that WSPs do anything.  Fact is, these written documents could be helpful but they've become so swollen with nonsense and fanciful language that they are little more than door stops. And don't blame me for that -- I'm just telling it like it is.  Two is the sanction here: a whopping $10,000 fine for what...failing to add more useless information to a useless document?  I'm not sure that a $100 or $1,000 fine isn't just as meaningful here.