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Klaus Pietschmann (* 1972 in Köln) ist ein deutscher Musikwissenschaftler. Er lehrt seit 2009 an der Universität Mainz.

Werdegang
Klaus Pietschmann studierte an der Universität zu Köln, an der Universität Florenz und an der Universität Münster Musikwissenschaft und Mittelalterliche Geschichte. 1997/98 war er am Deutschen Historischen Institut in Rom und wurde 2000 mit einer Arbeit über Kirchenmusik zwischen Tradition und Reform. Die päpstliche Kapelle und ihr Repertoire unter Papst Paul III. promoviert. Anschließend war er bis 2003 in Bonn und Köln in einem Forschungsprojekt über "Die Oper in Italien und Deutschland 1770–1830" tätig. Von 2003 bis 2006 war er Assistent von Hans-Joachim Hinrichsen und Laurenz Lütteken an der Universität Zürich, wo er auch habilitiert wurde. 2006 bis 2009 nahm er Assistenz- und Gastprofessuren in Bern und Graz wahr. 2009 wurde er ans Institut für Musikwissenschaft an der Universität Mainz berufen. Im Dezember 2021 wurde er als ordentliches Mitglied in die Akademie der Wissenschaften und der Literatur Mainz aufgenommen.

Pietschmann ist Stellvertretender Direktor von mainzed, dem Mainzer Zentrum für Digitalität in den Geistes- und Kulturwissenschaften.

2008 erhielt er den Preis für Geisteswissenschaften der Akademie der Wissenschaften zu Göttingen.

Schriften (Auswahl)
 Kirchenmusik zwischen Tradition und Reform. Die päpstliche Kapelle und ihr Repertoire im Pontifikat Pauls III. (1534–1549) (= CASCAM, Band 11). Vatikanstadt 2007
 Laboratorium des Wandels. Wien und die Diversifizierung der Oper um 1800. Habilitationsschrift Zürich 2006 (Druck i. V.)
 Das Erzbistum Köln in der Musikgeschichte des 15. und 16. Jahrhunderts. Kongressbericht Köln 2005 (= Beiträge zur rheinischen Musikgeschichte. Band 172). Merseburger, Kassel 2008.
 Hrsg. mit Hans-Joachim Hinrichsen: Jenseits der Bühne: Bearbeitungs- und Rezeptionsformen der Oper im 19. und 20. Jahrhundert. Symposiumsbericht der International Musicological Society 2007 (= Schweizer Beiträge zur Musikforschung, Band 15). Bärenreiter, Kassel 2010.
 Hrsg. mit Melanie Wald-Fuhrmann: Der Kanon der Musik. Theorie und Geschichte. Ein Handbuch. edition text + Kritik, München 2011, ISBN 978-3-86916-106-8.

Weblinks

Einzelnachweise

Musikwissenschaftler
Opernforscher
Hochschullehrer (Johannes Gutenberg-Universität Mainz)
Deutscher
Geboren 1972
Mann

redpajama_set_name: RedPajamaWikipedia


text:
La trimetilammina è un'ammina terziaria di formula bruta N(CH3)3. Nella molecola di questa sostanza un atomo di azoto si trova al centro di un tetraedro: tre vertici sono occupati da un gruppo funzionale metilico (-CH3) ed il quarto da una coppia elettronica (lone pair), che conferisce basicità alla sostanza stessa. La trimetilammina è un prodotto della decomposizione di piante ed animali, in particolare del pesce, al quale conferisce il caratteristico odore.

Caratteristiche
La trimetilammina è un composto incolore, igroscopico ed infiammabile, dal caratteristico odore "di pesce". In concentrazioni elevate l'odore è invece più simile a quello dell'ammoniaca. A temperatura ambiente si trova allo stato gassoso e viene comunemente commercializzata in bombola o in soluzione acquosa al 40%.

La trimetilammina è una base di Lewis e può reagire con l'acqua o con un altro donatore di ioni idrogeno (H+), formando lo ione trimetilammonio. Dalla reazione con cloruro di idrogeno anidro si ottiene cloruro di trimetilammonio, un composto solido di colore bianco. Dalla reazione con acido cloridrico si ottiene cloridrato di trimetilammina in soluzione acquosa.

Sintesi
La trimetilammina può essere sintetizzata tramite una reazione catalitica tra ammoniaca e metanolo a circa 300 °C utilizzando come catalizzatore ossido di alluminio:

3 CH3OH + NH3 -> (CH3)3N  +  3 H2O

Questa reazione produce anche dimetilammina (CH3)2NH e metilammina CH3NH2.
Un'altra  reazione di sintesi è quella tra cloruro di ammonio e formaldeide:

9(CH2=O)n + 2n NH4Cl -> 2n (CH3)3N*HCl + 3nH2O + 3nCO2 ^

Usi
La trimetilammina è impiegata nella sintesi della colina e dell'idrossido di tetrametilammonio. Si impiega anche nella produzione di fattori di regolazione della crescita delle piante, di alcune resine a scambio ionico e nella sintesi organica per la produzione di agenti acceleranti per gomme sintetiche.

Trimetilaminuria

La trimetilaminuria è una malattia genetica che comporta l'incapacità dell'organismo di metabolizzare la trimetilammina assunta per via alimentare. Nei soggetti affetti si riscontra il tipico odore di pesce nel sudore, nell'alito e nelle urine a seguito della consumazione di cibi ricchi di metilammine. Responsabile di questa malattia è il difetto di un gene recessivo presente in un autosoma, che comporta una carenza di enzima trimetilammina ossidasi.

Note

Altri progetti

Alchilammine


Tian Chen is the director of product for Al Jazeera Media Network, focused on research and development. He previously headed up the Al Jazeera America products and innovations group, responsible for all end-points outside of broadcast, which included apps for mobile, tablet and connected devices. He was previously with HBO, where he focused on strategic investments for digital workflows and TV Everywhere/OTT build-out. Prior to this, Tian held a number of roles with Grab Networks and Anystream, focused on digital media production and distribution. He has worked directly with clients, including Disney/ABC, NBCUniversal, Sony, Warner Bros., and Turner.


Choose to be a part of an integral team who strives to meet the needs of our residents. All positions within this organization play an important role, and we depend on you to work in a positive, professional, and compassionate manner. While each of us may have different individual responsibilities, we all have one basic goal: to provide the best care for our residents. To ensure the highest standards of service, our residents require the combined efforts of us all. We share in the obligations and accomplishments of Sauer Health Care, and the feeling of satisfaction and fulfillment that result from our service to others. It is our hope that you will find your work at Sauer Health Care pleasant, interesting and gratifying, and that you will be with us for many years to come.
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THAILAND/CAMBODIA – As reported by the Bangkok Post: "Army officers have been sent to negotiate with Cambodian authorities and the owner of a casino in Poipet about the release of nine Thai gamblers being held for a 90 million baht ($2.3 million) scam.
"The five men and four women include a relative of celebrity socialite Chao Kokaew Prakaikavin na Chiang Mai.
"They allegedly planted a microchip in a betting chip and cheated the casino out of 90 million baht.
"Army spokesman Col Somkhuan Saengpattranet said a border coordinating team would negotiate with local Cambodian authorities and the owner of Star Vegas casino in Poipet, opposite Sa Kaew's Aranyaprathet district.
"…The casino management suspected them of cheating and asked to search one of the women. They found a microchip implanted in a betting chip and a radio device attached to her leg…"


statuer verb conjugation to all tenses, modes and persons.
Search the definition and the translation in context for " statuer", with examples of use extracted from real-life communication.
statuer French verb: future, participle, present, subjunctive, conditional auxiliary verb être or avoir. Translate statuer in context, with examples of use and see statuer definition.
Voitures Modèles 10 Chaussure Supérbé De Bmw Puma ©2018 Reverso-Softissimo. All rights reserved.


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Business Continuity Planning and Lessons From the COVID-19 Pandemic
In February 2019, FINRA published Regulatory Notice 19-06, launching a retrospective review of Rule 4370 (Business Continuity Plans and Emergency Contact Information) to assess its effectiveness and efficiency (the BCP Rule Review). The COVID-19 pandemic, beginning in early 2020, caused unprecedented regulatory and operational impacts on member firms and other market participants, as well as regulators. During the early stages of the pandemic and while the BCP Rule Review was still underway, FINRA published Regulatory Notice 20-08 (March 2020) encouraging each member firm to review its business continuity plan (BCP) to consider pandemic preparedness and to review its emergency contacts to ensure that FINRA has a reliable means of contacting the firm.
During the pandemic, business continuity plans were implemented as member firms adapted swiftly to prioritize the health and safety of firm personnel and investors, while maintaining the public's access to capital markets. FINRA also provided regulatory relief and guidance, as appropriate, to member firms, firm personnel and investors as they navigated through pandemic-related impacts.
Further, to understand broader pandemic-related regulatory and operational impacts on member firms and other stakeholders, in December 2020, through Regulatory Notice 20-42, FINRA launched a retrospective review on lessons learned from member firms and their customers' experiences during the pandemic (the Pandemic Review). In Regulatory Notice 20-42, FINRA sought feedback from firms about their experiences in a range of areas, including how member firms' operations and business models may have changed during the public health crisis and may potentially evolve if the crisis persisted. FINRA further requested comment on whether it should consider changes to its rules, operations or administrative processes to address lessons learned during the pandemic or to respond to the anticipated long-term impacts of the pandemic on member firms and investors. As part of the Pandemic Review, FINRA sought to further validate its assessment of Rule 4370 in connection with the discrete BCP Rule Review.
Based on the BCP Rule Review and the Pandemic Review, both of which involved extensive feedback from a wide range of internal and external stakeholders, FINRA has determined to maintain Rule 4370 without change. This Notice summarizes the retrospective rule review process, the predominant themes that emerged from stakeholder feedback and resulting actions in both reviews, and provides guidance to member firms.
Questions regarding this Notice should be directed to:
Jeanette Wingler, Associate General Counsel, Office of General Counsel (OGC), at (202) 728-8013;
Sarah Kwak, Associate General Counsel, OGC, at (202) 728-8471; or
Patricia Ledesma, Senior Economist, Office of the Chief Economist, at (202) 728-8461.
Retrospective Review Process
FINRA periodically reviews its rules to determine whether they are meeting their intended objectives by reasonably efficient means, particularly in light of industry, market, technology, and other environmental changes. The retrospective review process typically has two phases: the assessment phase and the action phase. The assessment phase begins with the launch of a Regulatory Notice soliciting comment from all member firms and other interested external stakeholders. As part of the assessment phase, FINRA obtains input from several of its advisory committees, comprising firms of different sizes and business models and investor protection advocates, as well as its operating departments. If appropriate, FINRA may solicit feedback through a confidential survey distributed to all member firms to validate the feedback received through the comment process and to provide an additional opportunity for all members to provide input on the effectiveness and efficiency of the rule or rule set.
The action phase implements any recommendations arising from the assessment, which could include, among others, changes to the rule or its administration. Not every assessment includes a recommended rule change. The assessment may conclude that a rule remains relevant and appropriately tailored to meet its objectives. However, to the extent action involves modification of rules, FINRA will separately engage in its usual rulemaking process to propose amendments to the rules based on the findings. This process will include input from FINRA's advisory committees and an opportunity for comment on specific proposed revisions in a Regulatory Notice or rule filing with the Securities and Exchange Commission (SEC), or both.
To conduct the BCP Rule Review, Regulatory Notice 19-06 posed several questions pertaining to member firms' experiences with the rule; the economic impacts, including costs and benefits, associated with creating, maintaining or updating a BCP; and the substance and activation of member firms' BCPs (e.g., whether a BCP addresses specific types of significant business disruptions such as cyber events, terrorist attacks, pandemics or natural disasters). FINRA received two comment letters.1 FINRA subsequently solicited additional feedback through a confidential pre-pandemic survey distributed to all member firms to validate the feedback received during the comment process and to provide an additional opportunity for all members to provide their views on Rule 4370. The survey collected 288 responses, which represented approximately eight percent of FINRA member firms. In the summer of 2020, FINRA sought to supplement the input received by speaking directly with some internal and external stakeholders following the widespread activation of BCPs by member firms due to the pandemic.
To conduct the Pandemic Review, Regulatory Notice 20-42 solicited feedback on lessons learned from member firms and their customers' experiences during the pandemic covering a range of topics, including the effectiveness of business continuity planning, among others. FINRA further requested comment on whether to consider changes to FINRA rules, operations or administrative processes in response to pandemic experiences or to address anticipated long-term impacts of the pandemic on member firms and investors. In response, FINRA received 32 comment letters spanning a broad range of issues.2 For the BCP Rule Review and Pandemic Review, FINRA also obtained input from several advisory committees, and in meetings with staff from several trade associations. In addition, FINRA obtained the perspective of its relevant operating departments.
BCP Rule Review
Rule Requirements
Rule 4370 requires a member firm to create, maintain, review at least annually and update upon any material change, a written BCP identifying procedures relating to an emergency or significant business disruption. BCPs should be reasonably designed to enable a member firm to meet its existing obligations to customers and address existing relationships with other broker-dealers and counterparties. Each member firm has flexibility to tailor its BCP to the size and needs of its business, provided that the BCP addresses the enumerated minimum elements set forth in Rule 4370 to the extent applicable and necessary to the firm's business.3
Rule 4370 also requires each firm to provide (and promptly update upon any material change) to FINRA via electronic process or other means as FINRA may specify, prescribed emergency contact information, including the designation of two emergency contact persons, both of whom must be associated persons.4 Member firms may register and update their emergency contact persons through the FINRA Contact System (FCS).5
Findings and Observations
The BCP Rule Review, as well as the related feedback received during the Pandemic Review,6 confirmed the continuing value and effectiveness of Rule 4370 and its flexible, non-prescriptive approach, and so FINRA proposes to maintain the rule without change.
The majority of stakeholders indicated that Rule 4370 works well and expressed the view that the rule's flexible, non-prescriptive, and risk-based approach has been effective in ensuring firms of all sizes are prepared for potential business disruptions. Commenters to Regulatory Notice 19-06 indicated that the rule has been effective at ensuring member firm preparedness for a wide range of potential business disruptions. Stakeholders conveyed their appreciation for the rule's straightforward approach and expressed a preference for maintaining the current flexible approach.7 In addition, commenters to Regulatory Notice 20-42 generally indicated that the rule worked well and expressed the view that the rule provided member firms with the necessary flexibility to successfully execute their BCPs and respond to the pandemic.8
As described below, some stakeholders suggested incorporating additional prescriptive requirements into the rule and a BCP testing requirement. Some stakeholders suggested eliminating the requirement that a member firm provide the BCP disclosure to customers at account opening, and indicated that, as a general matter, additional guidance on effective practices would be welcome.
Some stakeholders suggested that FINRA consider amending the rule to expressly address a BCP testing requirement, with some supporting a mandatory testing requirement, while other stakeholders recommended that such requirement be left to the discretion of the firm. Several commenters to Regulatory Notice 20-42 stated that members regularly test their BCPs and suggested that testing was helpful in preparing firms for activating their BCPs during the pandemic.9
While the rule does not specifically mandate BCP testing, the rule does require a firm to conduct an annual review of its BCP to determine whether any modifications are necessary in light of changes to the firm's operations, structure, business or location. FINRA has publicly stated that this review may encompass testing BCP functionality, which would help a firm determine whether the BCP is "reasonably designed."10 In addition, the 2019 Report on Examination Findings and Observations (2019 Exam Report) includes annual testing as an observed effective practice used by member firms to fulfill their obligations under the rule.11
Providing BCP Disclosure to Customers at Account Opening
Some stakeholders questioned the need to provide the BCP disclosure at account opening. These stakeholders suggested eliminating the temporal aspect of the BCP disclosure. Some external stakeholders indicated that the requirement to provide written BCP disclosure at customer account opening adds significant volume to the account opening packet and is more granular than necessary for customers.
Approximately 68 percent of survey respondents indicated that they do not believe that it is particularly useful for firms to provide a copy of the firm's BCP to new customers. Survey respondents shared a variety of reasons for this view. Other views included that information contained in the BCP is confidential and that it is too much information for customers to understand. On the other hand, approximately 32 percent of survey respondents indicated that providing the BCP to customers was beneficial, stating that some customers do ask about the BCP or have read it.
FINRA has published guidance stating that firms are not required to disclose their actual BCP, including any proprietary information, but rather can provide appropriate levels of summary information about how the firm will address the possibility of a future significant business disruption and how the firm plans to respond to events of varying scope.12 FINRA has also stated that member firms can satisfy their delivery obligations under FINRA rules by using electronic media, subject to compliance with standards established by the SEC on the use of electronic media for delivery purpose.13 Because survey respondents indicated that some customers request and read the BCP, FINRA does not propose to alter the current disclosure requirement.
Minimum Elements of a BCP
One stakeholder recommended supplementing the rule's minimum BCP requirements set forth under Rule 4370(c) to include other categories such as critical data backup, cloud usage and storage, vendor relationships, and alternative business locations. The stakeholder also suggested a requirement for a firm to adopt a separate disaster recovery plan (DRP) and an incident response plan and to integrate those plans with the BCP. The majority of survey respondents indicated agreement that the DRP and incident response plans should be integrated with the BCP if the firm has these plans.
In comments to Regulatory Notice 20-42, one stakeholder suggested adding criteria to Rule 4370 that address sustained and catastrophic disruptions, such as providing long-term secure remote access to firm systems; creating rapid succession plans for lost principals and employees; and alternative procedures for supervising employees. Some stakeholders conveyed their observations about the industry's increased use of and reliance on third-party vendors, and that the rule does not specifically address third-party dependencies and their attendant risks, particularly concentration risk. In contrast, the majority of stakeholders suggested retaining the rule's current approach and allowing a member firm the flexibility to tailor the BCP to the size and needs of its business.
Based on stakeholder feedback, including feedback subsequent to the survey regarding firms' experiences during the pandemic, we believe that the rule's flexible, non-prescriptive and risk-based approach has been effective in ensuring firms of different sizes are prepared for potential business disruptions. Moreover, the rule is intended to ensure that a firm can meet its existing obligations to customers in a significant business disruption regardless of the length of the business disruption. Accordingly, FINRA does not propose amending the minimum elements of a BCP at this time.
Firms that have adopted separate DRPs or incident response plans may benefit from integrating the plans with the BCP as suggested by the survey respondents. Regarding third-party vendors, FINRA recently addressed more broadly member firms' responsibilities when outsourcing responsibilities to third parties.14
Triggering Events
One of the questions in the survey asked respondents to indicate the types of events that triggered their BCP. Technology system failures, natural disaster or weather-related incidents, and infrastructure failures (e.g., blackouts or grid failures) were the most commonly cited triggering events for activating the BCP prior to the COVID pandemic.15 While the survey distributed during the BCP Rule Review indicated that a greater proportion of large firms activated their BCP in the last five years than small firms, there was widespread activation of BCPs by member firms of different sizes during the pandemic. During the Pandemic Review, some stakeholders indicated that they expressly address pandemics as triggering events in their BCPs, while other commenters indicated that they address disaster events or public health events, but not pandemics specifically, as triggering events. Some stakeholders indicated that they intended to revise their BCPs to expressly address pandemics.
Remote Work Arrangements
Some external stakeholders conveyed that use of remote work arrangements and cloud computing services prior to the pandemic made member firms better positioned to transition to a remote work environment during the pandemic.16 External stakeholders indicated that some firm BCPs incorporated temporary use of alternate work locations but did not incorporate widespread and continued use of remote work arrangements. In response to the pandemic, some firms revised their BCPs to expressly incorporate remote work arrangements.
Some stakeholders expressed an interest in having additional guidance on BCP effective practices. One stakeholder recommended that FINRA provide additional guidance on effective practices pertaining to data protection and failover testing tailored by business model or size, internal and external communication between employees, counterparties, vendors and government regulators during a BCP event, industry-wide training, an assessment of mission critical systems, and cybersecurity. The majority of survey respondents agreed that guidance or effective practices would help their firm prepare a more comprehensive BCP. In contrast, another stakeholder stated that the current guidance and administrative processes are efficient and effective. The stakeholder indicated that due to the evolving threat environment, prescriptive guidance to business continuity planning may not result in significant benefits.
Beginning in March 2020, FINRA published: (1) guidance and temporary regulatory relief for member firms due to the pandemic, including FAQs regarding business continuity planning; (2) Regulatory Notice 20-08 regarding pandemic-related business continuity planning, guidance and regulatory relief; and (3) Regulatory Notice 20-16 sharing practices implemented by firms to transition to, and supervise in, a remote work environment during the pandemic.17 In addition, FINRA published a revised Small Firm Business Continuity Plan Template to modernize the template and incorporate feedback received during the retrospective review (e.g., to reflect increased use of remote work arrangements). The template is an optional tool for member firms.
Pandemic Review
The Pandemic Review sought feedback from member firms about pandemic-related regulatory and operational impacts on firms and other stakeholders. In addition to soliciting feedback on business continuity planning, the Pandemic Review also sought comments on other areas covering remote offices, alternative work arrangements and remote inspections; engaging with FINRA and FINRA processes; qualification examinations; investors' experiences; and the economic impacts of specified FINRA rules. Given the exigent health and safety concerns and the significant impacts of the pandemic on member firms, investors and other stakeholders, FINRA provided guidance and temporary regulatory relief to firms, associated persons and other individuals through the issuance of FINRA communications, FAQs and temporary rule amendments, without compromising critical investor protection measures or fair processes.18 In addition, FINRA launched several initiatives to respond to issues and questions that arose during the pandemic.
FINRA Guidance, Temporary Regulatory Relief and Initiatives
FINRA's guidance, temporary regulatory relief and initiatives during the pandemic include:
Regulatory Notice 20-08 (March 2020) regarding pandemic-related business continuity planning, guidance and regulatory relief to member firms from some requirements;
Regulatory Notice 20-13 (May 2020) reminding firms of the risks and challenges of fraud during the pandemic;
Regulatory Notice 20-16 (May 2020) sharing practices implemented by firms to transition to, and supervise in, a remote work environment during the pandemic;
Information Notice 3/26/20 providing cybersecurity measures to consider as firms respond to the pandemic;
Regulatory Notice 21-29 noting recent trends in examination findings, observations and disciplinary actions and providing questions firms may consider when evaluating their systems, procedures and controls relating to third-party vendor management;
2021 Report on FINRA's Examination and Risk Monitoring Program identifying rule and key related considerations for member firm compliance programs, summarizing noteworthy findings from recent examinations, outlining effective practices that FINRA observed during its oversight, and providing additional resources that may be helpful to member firms in fulfilling their compliance obligations;
issuing several notices and other communications to alert firms about rising threats relating to cybersecurity threats, including imposer websites,19 phishing attacks20 and ACH fraud;21
holding roundtable discussions with firms and issuing Regulatory Notice 21-18 (May 2021) to share effective practices to address risks relating to online takeover attempts, which increased during the pandemic;
delivering a series of virtual panels to assist firms with transitioning to remote work, including but not limited to remote inspections, supervision, arbitration, financial crime and cybersecurity;
issuing several FAQs providing guidance and temporary regulatory relief;
issuing an FAQ regarding the hosting of virtual business entertainment events or meetings;
adopting temporary amendments to FINRA rules;22
adopting amendments to Rule 1010 (Electronic Filing Requirements for Uniform Forms) to permit firms to obtain an electronic signature on the Form U4 and a conforming amendment to Rule 2263 (Arbitration Disclosure to Associated Persons Signing or Acknowledging Form U4);23
delivering an online testing service for candidates seeking to take some qualification exams remotely;24
publishing several Investor Insights regarding the effects of the pandemic;25
forming a COVID Fraud Task Force in March 2020 to establish a coordinated response across the organization to potential COVID-related fraud in the broker-dealer industry and in U.S. markets; and
providing as a resource to member firms a list of active state shelter-in-place and stay-at-home orders that imposed workplace restrictions at the start of the COVID-19 pandemic.
FINRA's pandemic-related guidance, temporary regulatory relief and initiative information, as well as links to SEC pandemic-related guidance and resources relevant to member firms, are available on a consolidated COVID-19 webpage that FINRA created at the outset of the pandemic.
Remote Offices, Remote Inspections and MAP Rules
To mitigate the impacts of the pandemic, member firms have relied heavily on remote offices and alternative work arrangements (e.g., working from home or a backup or recovery location) for a broad range of personnel. Commenters to Regulatory Notice 20-42 most frequently raised issues related to member firms' use of remote offices and remote inspections after the pandemic. Several commenters also expressed concern about implications under the Membership Application Program (MAP) rules if member firms are required to register many offices due to remote work.26 As discussed below, FINRA is considering these interrelated issues and potential changes to the current framework.
Remote Offices/Registration
Commenters to Regulatory Notice 20-42 generally expect strong continued interest in remote work after the pandemic. Commenters generally stated that technology, including centralized firm systems and supervision, supported the transition to remote work during the pandemic. Many commenters emphasized that the "branch office" and "office of supervisory jurisdiction" (OSJ) definitions in FINRA Rule 3110 (Supervision) should be revisited to reflect member firms' use of technology and evolving work arrangements. Several commenters expressed concern that without amendments, personal residences of many associated persons will need to be registered (and inspected) to facilitate remote work arrangements after the pandemic. Several commenters supported a transition of the office definitions to a risk-based approach (e.g., whether funds and securities are handled at the location), rather than a location-based approach.
Rule 3110 and Form BR share definitions.27 One commenter noted that it does not believe the definitions should be amended without a full vetting of the circumstances under which more lenient definitions may be abused or lead to risks to investors. This commenter stated that the desire to increase the use of remote offices and alternative work arrangements does not change the regulatory reasons behind the definitions.
FINRA is engaging with stakeholders to reevaluate Rule 3110(f) (Definitions) and the potentially significant supervisory impacts that may result from changing the current framework for defining a branch office and the exclusions.
Remote Inspections under Rule 3110
In part due to the changing office environment noted above, commenters generally supported allowing member firms to conduct remote inspections to satisfy their Rule 3110(c) (Internal Inspections) obligations. However, some stakeholders emphasized the continued value of firms conducting onsite inspections. Member firms and trade associations indicated that they believe that firms' remote inspections have been effective. Several commenters to Regulatory Notice 20-42 also indicated that their remote inspection findings for 2020 were similar to onsite inspection findings for prior years.
Several member firms and trade associations supported the transition to a risk-based approach to allow for remote inspections of lower risk locations. Some commenters to Regulatory Notice 20-42 indicated that, even if remote inspections were permitted, onsite inspections would continue to have a role (e.g., for higher risk locations or for each location on a periodic basis). Several commenters shared information regarding how they conduct remote inspections and why they believe the approach is effective.
Beginning in 2020, FINRA adopted two temporary rules to account for pandemic-related operational challenges related to satisfying Rule 3110(c) obligations. Rule 3110.16 extended the time by which firms could satisfy their year 2020 inspection obligations to March 31, 2021. Rule 3110.17 permitted member firms to complete their inspections of all offices and non-branch locations for year 2020 remotely by March 31, 2021, and for year 2021 remotely by December 31, 2021, subject to specified terms.28 In September 2021, FINRA extended Rule 3110.17 to include calendar year 2022 inspection obligations through June 30, 2022.29
FINRA is considering modifications to firms' obligations under Rule 3110(c) and the current framework for defining offices as an OSJ, branch office and non-branch location.
As member firms fully implement their return-to-office plans, they may need to register as branch offices some of their currently temporary locations or new locations established as a result of the "new normal." For many member firms, resuming the requirement to designate and register offices on Form BR may result in an increase in the number of offices (registered or unregistered) that could exceed the MAP rule's safe harbor thresholds or could otherwise represent a material change in business operations that would require the submission of a continuing membership application (CMA) for FINRA's approval. Several commenters expressed concern about how the potential increase in the number of offices due to remote work arrangements could require a CMA under the MAP rules.30 Several commenters offered suggestions to mitigate the impact of such a scenario. For example, one commenter offered three potential solutions: (1) remove the requirement to submit a CMA and permit a member firm to rely on MAP's safe harbor provision if such firm (that is not a defined disciplined firm under FINRA rules) would like to expand the number of office locations with no material change to the products and services being offered by the member firm; (2) carve out certain types of office locations, including a primary residence, from the business expansion application requirement, which could be effected in tandem with redefining "OSJ," "branch office" and "non-branch location"; or (3) expand the annual thresholds for new offices.
FINRA is considering the concerns and potential ways to find a balanced approach in assisting members navigate to the "new normal," including the application of the MAP rules.
Engaging with FINRA and FINRA Processes
Engagement with member firms has been a critical part of FINRA's assessment of the need for and appropriateness of guidance, temporary regulatory relief and other initiatives during the pandemic. In addition, FINRA has underscored the importance of member firms communicating with FINRA regarding whether, among other things, examinations, regulatory filings, and responses to FINRA inquiries, matters and investigations may be impacted by the pandemic.
During the pandemic, we engaged in ongoing conversations with firms to discuss the impact of the pandemic on their business and their compliance programs, including but not limited to, transition to remote work, remote supervision, increased market volatility, new cybersecurity threats and return to office plans. This approach allowed us to monitor emerging trends and develop a deeper understanding of the risks facing firms in each business model across all firm groupings – Retail, Diversified, Carrying & Clearing, Capital Markets and Trading & Execution – and proactively provide more nuanced and targeted regulatory relief and guidance.
We are also continuing to evaluate and continuously improve our exam and risk monitoring programs and process, including improving tools, processes and guidance to enhance our interactions with firms on an on-going basis and during exams.
A commenter to Regulatory Notice 20-42 encouraged FINRA to: (1) review the mechanisms used by member firms to provide required regulatory notifications to FINRA with an eye to potential enhancements to the notice fields; and (2) include additional mechanisms, as alternative means of compliance, to give options to member firms. FINRA is considering technology solutions to address these processes.
Leveraging technology has been critical to carrying out FINRA's regulatory mission and responsibilities. For example, FINRA temporarily amended certain timing, method of service and other procedural requirements in FINRA rules to allow, among other things, service of some documents by email.31 In addition, as noted above, FINRA adopted amendments to Rule 1010 to permit firms to obtain an electronic signature on the Form U4 and a conforming amendment to Rule 2263.32
Qualification Examinations
Due to health and safety concerns and testing center closures and capacity constraints, FINRA provided relief to persons seeking to take qualification examinations. Notably, beginning in 2020, FINRA extended open examination enrollment windows and extended the period for persons to function as principals or operations professionals without passing the appropriate qualification examination as allowed by FINRA Rules 1210.04 and 1220(b)(3)(B), respectively.33
In addition, since July 2020, FINRA and NASAA have delivered an online testing service for candidates seeking to take FINRA's Securities Industry Essentials (SIE), Series 6, and Series 7 exams and NASAA's Series 63, Series 65 and Series 66 exams remotely. Beginning in February 2021, FINRA adopted an interim accommodation request process to allow candidates to take additional FINRA exams online, including the Series 24, Series 57, Series 79 and Series 99 exams.34
Most commenters to Regulatory Notice 20-42 supported allowing candidates to take qualification exams remotely and expanding the tests that are offered remotely. However, some commenters indicated challenges in scheduling onsite and remote qualification examinations due to limited capacity. Some commenters also indicated technical issues with taking exams remotely (e.g., lack of broadband internet in rural locations or incompatibility of test software with firm computers).
FINRA will continue to monitor the delivery of qualification exams, including vendor performance and online delivery of some exams, and address any issues that arise. In addition, FINRA is considering and discussing with other stakeholders the potential role of online examinations post-pandemic.
Virtual Arguments and Hearings
While FINRA postponed in-person arbitration hearings and mediation sessions in response to the pandemic, FINRA permitted arbitration hearings and mediation sessions to proceed virtually either by party agreement or arbitration panel order. From March 2020 through November 2021, FINRA had 589 cases with one or more virtual evidentiary hearings.
Some commenters to Regulatory Notice 20-42 suggested changes to virtual arguments and hearings for greater effectiveness. For example, the University of Miami School of Law Investor Rights Clinic suggested that "FINRA should continue providing investors the option to conduct arbitration proceedings on Zoom but should make this option available at the investor's choice without the need for agreement by the parties or a contested motion."
FINRA has temporarily amended its rules to allow evidentiary hearings in disciplinary actions, eligibility proceedings, temporary and permanent cease and desist orders, and appeals of MAP decisions to be conducted by video conference, if warranted by the current COVID-19-related public health risks posed by an in-person hearing. The temporary amendments also allow oral arguments in appeals of disciplinary actions to be conducted by videoconference. The temporary amendments are in effect through March 31, 2022, pending any future extensions.35
FINRA is also considering our approach to offering virtual arbitration pre-hearing conferences and hearings more broadly. FINRA Dispute Resolution Services (DRS) has formed a Zoom Arbitration Task Force with industry representatives and investor counsel to help us continue to improve our future Zoom offerings. In addition, effective August 2, 2021, all FINRA DRS hearing locations are open for in-person proceedings.36
Communications with the Public
Due to changed communications practices during the pandemic, FINRA published FAQs regarding application of FINRA rules to some types of virtual communications (e.g., live video or audio conferencing platforms, virtual meetings hosted or attended by third-parties and visual aids, such as whiteboard or dynamic charts, used during live presentations).37 The FAQs clarified that the supervision requirements for virtual communications depend on the nature and number of persons participating in the communication as well as the form of the communication (e.g., unscripted live appearance, audio, text, graphics, or video). The FAQs also discussed circumstances under which a firm may become entangled with or adopt the virtual communications of third parties.
1 The two comment letters were from: Christopher W. Bok, Director, Financial Information Forum (FIF) (April 25, 2019) and Thomas M. Wagner, Managing Director, Securities Industry and Financial Markets Association (SIFMA) (April 26, 2019).
2 The comment letters were from: William C. Anderson, Chief Compliance Officer, American Funds Distributors, Inc., (Feb. 16, 2021) (American Funds); Richard Izzo, President, Association of Registration Management, Inc. (Feb. 19, 2021) (ARM); Kelli McMorrow, Head of Government Affairs, American Securities Association (Feb. 16, 2021) (ASA); John Chuff, President, BA Securities, LLC (Feb. 16, 2021) (BA Securities); Eric Arnold and Clifford Kirsch of Eversheds Sutherland on behalf of the Committee of Annuity Insurers (Feb. 16, 2021) (CAI); Michael Decker, Senior Vice President, Bond Dealers of America (Feb. 16, 2021) (BDA); Christopher W. Anderson, Chief Compliance Officer, Caldwell Sutter Capital, Inc. (Feb. 16, 2021) (Caldwell); Seth A. Miller, General Counsel, Executive Vice President, and Chief Risk Officer, Cambridge Investment Research, Inc. (Feb. 16, 2021) (Cambridge); Mark Quinn, Director of Regulatory Affairs, Cetera Financial Group (Feb. 16, 2021) (Cetera); Matthew J. Sugden, Vice President, Compliance, Commonwealth Financial Network (Feb. 16, 2021) (Commonwealth); Merri Jo Gillette, Deputy General Counsel, Edward Jones (Feb. 10, 2021) (Edward Jones); Seve Faure (Feb. 11, 2021); Carrie L. Chelko, Chief Compliance Officer, Fidelity Brokerage Services LLC, Richard O'Brien, Chief Compliance Officer, National Financial Services LLC, Fidelity Distributor Company LLC, Digital Brokerage Services LLC (Feb. 16, 2021) (Fidelity); Nanette K. Chern, Susan K. Moscaritolo, Susan L. La Fond, Jennifer A. Brunner, Chief Compliance Officers, Foreside family of companies (Jan. 26, 2021) (Foreside); Robin Traxler, Senior Vice President, Financial Services Institute (Feb. 11, 2021) (FSI); Kenneth I. Schindler, Chief Compliance Officer, GWFS Equities, Inc. (Feb. 9, 2021) (GWFS); Peggy E. Chait, Managing Director, and Howard Spindel, Senior Managing Director, Integrated Solutions (Feb. 16, 2021) (Integrated Solutions); Carlos Barrientos, Invex (Feb. 12, 2021) (Invex); Logan Sandler, Gabrielle Craft, and Alexandra Tipton, legal interns, University of Miami School of Law Investor Rights Clinic (Feb. 16, 2021) (IRC); Emily Micale, Director, Federal Regulatory Affairs, Insured Retirement Institute (Feb. 16, 2021) (IRI); Will H. Fuller, EVP, President, Annuities, Lincoln Financial Distributors & Lincoln Financial Network (Feb. 2021) (Lincoln); Michelle Bryan Oroschakoff, Chief Legal Officer, LPL Financial LLC (Feb. 16, 2021) (LPL); Jennifer Lewis, Lead Counsel, Broker-Dealer and Investment Adviser Practice Group, MML Investor Services, LLC (Feb. 16, 2021) (MML); Lisa Hopkins, President, North American Securities Administrators Association (Feb. 23, 2021) (NASAA); James Rabenstine, Vice President, Chief Compliance Officer, Nationwide Financial Services, Inc. (Feb. 11, 2021) (Nationwide); Matt Rothchild (Jan. 20, 2021) (Rothchild); Barbara Armeli, Senior Vice President, Chief Compliance Officer, Charles Schwab & Co., Inc. (Feb. 12, 2021) (Schwab); Kevin Zambrowicz, Managing Director & Associate General Counsel, Securities Industry and Financial Markets Association (Feb. 16, 2021) (SIFMA); Ruben Huertero, Legal Intern, Christine Lazaro, Director of the Securities Arbitration Clinic and Professor of Clinical Legal Education, Securities Arbitration Clinic at St. John's University School of Law (Feb. 16, 2021) (St. John's); Marc Gilman, General Counsel and VP of Compliance, Theta Lake, Inc. (Feb. 15, 2021) (Theta Lake); James T. McHale, Chief Compliance Officer, Wells Fargo Advisors (Feb. 16, 2021) (Wells Fargo); and Jennifer L. Szaro, XML Financial Group (Feb. 15, 2021) (XML Financial).
3 Rule 4370(c) requires that each BCP, must at a minimum, address: (1) data back-up and recovery (hard copy and electronic); (2) all mission critical systems; (3) financial and operational assessments; (4) alternate communications between customers and the member; (5) alternate communications between the member and its employees; (6) alternate physical location of employees; (7) critical business constituent, bank, and counter-party impact; (8) regulatory reporting; (9) communications with regulators; and (10) how the member will assure customers' prompt access to their funds and securities in the event that the member determines that it is unable to continue its business.
In June 2021, a firm was ordered to pay $70 million for systemic supervisory failures and customer harm, including, among other issues, failure to create a reasonably designed BCP to cover technology-related emergencies and to address all "mission critical systems" as required under Rule 4370. For example, the firm's BCP was limited to events that physically prevented employees from working from the firm's premises. The firm's BCP was not reasonably tailored to the firm's online business and large customer base. See FINRA press release (June 30, 2021). See also the 2021 Report on FINRA's Risk Monitoring and Examination Activities stating that Rule 4370 applies to denials of service and other interruptions to members' operations.
4 This requirement is intended to ensure that FINRA has a reliable means of contacting each member firm in the event of an emergency. One contact must be a member of senior management and a registered principal of the member firm and the second contact, if not a registered principal, must be a member of senior management who has knowledge of the firm's business operations. For a firm that has only one associated person (e.g., a sole proprietorship without any other associated persons), the second emergency contact person may be an individual, either registered with another firm or nonregistered, who has knowledge of the member firm's business operations, such as the firm's attorney, accountant or clearing firm contact.
5 Visit FINRA's FCS webpage to access the system.
6 The comment letters that specifically addressed BCP were from: BDA; Cambridge; Commonwealth; Edward Jones; Fidelity; Foreside; FSI; GWFS; Integrated Solutions; Invex; LPL; MML; NASAA; SIFMA; and XML Financial.
7 Approximately 89 percent of survey respondents indicated their overall preference for the rule's existing flexibility over imposing more prescriptive measures.
8 See, e.g., comments from Commonwealth, Edward Jones, FSI, GWFS, MML, SIFMA and XML Financial.
9 See, e.g., comments from Edward Jones and XML Financial.
10 See Business Continuity Planning FAQ, Question and Answer 18. See also Regulatory Notice 13-25 (August 2013) (joint advisory stating, in part, that firms should consider conducting full BCP tests, stress tests, and staff training).
11 As discussed in the 2019 Report on Examination Findings and Observations, FINRA has found some member firms encountering challenges where their BCPs did not reflect certain market conditions, business models or other circumstances (e.g., BCPs that did not identify all mission-critical systems, BCPs that were not updated after significant operational changes, and firms that lacked sufficient capacity to handle increased call volumes and online activity during a disruption). The 2019 Exam Report includes some observed effective practices at member firms, including engaging in annual testing and incorporating test results into firm training.
12 See Business Continuity Planning FAQ, Question and Answer10 (suggesting the topics a disclosure should provide).
13 See Notice to Members 98-03 (January 1998).
14 See, e.g., Notice to Members 05-48 (July 2005) and Regulatory Notice 21-29 (Aug. 2021).
15 Approximately 26 percent of survey respondents cited technology system failures, approximately 22 percent cited natural disasters, and approximately 20 percent cited infrastructure failures.
16 The remote work arrangements prior to the pandemic included arrangements used to test a member firm's BCP, as well as regular flexible work arrangements for staff.
17 This guidance and temporary regulatory relief is available on FINRA's COVID-19 topic page.
18 FINRA previously provided guidance on pandemic preparedness in Regulatory Notice 09-59 (October 2009).
19 See Regulatory Notice 20-30 (August 2020).
20 See Regulatory Notice 20-12 (May 2020); Regulatory Notice 20-27 (August 2020); Regulatory Notice 20-35 (October 2020); Regulatory Notice 20-40 (November 2020); Regulatory Notice 21-08 (March 2021); Regulatory Notice 21-20 (June 2020); Regulatory Notice 21-22 (June 2021); Regulatory Notice 21-30 (August 2021).
21 See Regulatory Notice 21-14 (March 2021).
22 Pursuant to SR-FINRA-2020-040, FINRA has adopted temporary Supplementary Material .17 (Temporary Relief to Allow Remote Inspections for Calendar Year 2020 and Calendar Year 2021) under Rule 3110 to provide member firms the option, subject to specified requirements under the supplementary material, to complete remotely their calendar year 2020 and calendar year 2021 inspection obligations under Rule 3110(c) (Internal Inspections), without an on-site visit to the office or location. In September 2021, FINRA extended Rule 3110.17 to include calendar year 2022 inspection obligations through June 30, 2022. See SR-FINRA-2021-023.
Pursuant to SR-FINRA-2020-027, as extended by SR-FINRA-2020-042, SR-FINRA-2021-006, SR-FINRA-2021-019 and SR-FINRA-2021-031, FINRA has temporarily amended FINRA Rules 1015, 9261, 9524 and 9830 to allow hearings in connection with appeals of Membership Application Program decisions, disciplinary actions, eligibility proceedings and temporary and permanent cease and desist orders to be conducted by video conference, if warranted by the current COVID-19-related public health risks posed by an in-person hearing. The temporary amendments in SR-FINRA-2020-027 became operative on October 1, 2020, and are in effect through March 31, 2022, pending any future extensions.
Pursuant to SR-FINRA-2020-015, and as extended by SR-FINRA-2020-017, SR-FINRA-2020-022 SR-FINRA-2020-042, SR-FINRA-2021-006, SR-FINRA-2021-019 and SR-FINRA-2021-031, FINRA has temporarily amended certain timing, method of service and other procedural requirements in FINRA Rules 1012, 1015, 6490, 9132, 9133, 9146, 9321, 9341, 9349, 9351, 9522, 9524, 9525, 9559 and 9630. These temporary amendments are effective from May 8, 2020, through March 31, 2022, pending any future extensions.
Additional expired temporary rule amendments:
Pursuant to SR-FINRA-2020-019, FINRA adopted temporary Supplementary Material .16 (Temporary Extension of Time to Complete Office Inspections) under FINRA Rule 3110 (Supervision) that extended the time by which member firms were required to complete their calendar year 2020 inspection obligations under Rule 3110(c) to March 31, 2021.
Pursuant to SR-FINRA-2020-026 as extended by SR-FINRA-2020-043 and SR-FINRA-2021-005, FINRA adopted: (1) temporary Supplementary Material .12 (Temporary Extension of the Limited Period for Registered Persons to Function as Principals) under FINRA Rule 1210 (Registration Requirements); and (2) temporary Supplementary Material .07 (Temporary Extension of the Limited Period for Persons to Function as Operations Professionals) under FINRA Rule 1220 (Registration Categories) that extended the 120-day period that individuals designated prior to March 3, 2021 could function as a principal or Operations Professional without having successfully passed an appropriate qualification examination through June 30, 2021.
23 See SR-FINRA-2021-003. See FAQs regarding Rule 1010 (Electronic Filing Requirements for Uniform Forms) on COVID-19 FAQs.
24 Additional information regarding remotely proctored qualification exams is available at Coronavirus Impact on FINRA-Administered Exams.
25 See The Coronavirus Is Novel, but Crisis-related Scams Are Nothing New (Oct. 2020); COVID-19 Early Withdrawals (June 2020); Fraud and Your Investment Accounts During COVID-19 Pandemic (May 2020); Financial Peace of Mind in the Age of Coronavirus (March 2020); and Fraud and Coronavirus (COVID-19) (March 2020). The Investor Insight "COVID-19 Early Withdrawals" was published jointly by FINRA, NASAA and SEC staff. The Investor Insight "The Coronavirus Is Novel, but Crisis-related Scams Are Nothing New" was published jointly by NASAA and FINRA staff.
26 In Regulatory Notice 20-08, FINRA temporarily suspended the requirement to: (1) maintain updated Form U4 information regarding office of employment address for registered persons who temporarily relocate due to COVID-19; and (2) submit branch office applications on Form BR for any newly opened temporary office locations or space-sharing arrangements established as a result of the pandemic. In Regulatory Notice 20-08, FINRA stated that, when appropriate, we will publish a Regulatory Notice announcing a termination date for the regulatory relief that will provide member firms with time to make necessary operational adjustments.
27 Broker-dealers and state-registered investment advisers use Form BR (Uniform Branch Office Registration Form) for branch office registration, notice filing, closing or withdrawal in the appropriate jurisdictions or with SROs, including FINRA.
28 In 2020, FINRA adopted temporary Rules 3110.16 (Temporary Extension of Time to Complete Office Inspections) to extend the time by which a firm could complete its year 2020 inspections to March 31, 2021, and 3110.17 (Temporary Relief to Allow Remote Inspections for Calendar Year 2020 and Calendar Year 2021). Rule 3110.16 expired by its terms on March 31, 2021. See SR-FINRA-2020-019 and SR-FINRA-2020-040.
29 See SR-FINRA-2021-023.
30 FINRA IM-1011-1 (Safe Harbor for Business Expansion) creates a safe harbor for a firm that is seeking to expand its business in three categories, one of which pertains to the number of offices (registered or unregistered). Subject to specified conditions and thresholds, a member firm may increase the number of offices without filing a CMA because such expansion is presumed not to be a material change in business for purposes of FINRA Rule 1017 (Application for Approval of Change in Ownership, Control, or Business Operations).
31 See SR-FINRA-2020-015, and as extended by SR-FINRA-2020-017, SR-FINRA-2020-022 SR-FINRA-2020-042, SR-FINRA-2021-006 SR-FINRA-2021-019 and SR-FINRA-2021-031.
33 See Coronavirus Impact on FINRA-Administered Exams and SR-FINRA-2020-026, as extended by SR-FINRA-2020-043 and SR-FINRA-2021-005. Any pandemic-related exam window extension expired no later than June 30, 2021. The temporary relief permitting persons to function as principals or operations professionals without passing the appropriate qualification examination as allowed by FINRA Rules 1210.04 and 1220(b)(3)(B), respectively, expired by its terms on June 30, 2021.
34 See FINRA Online Exam Administration Request Form. To address the ongoing challenges facing exam candidates by the pandemic, effective February 24, 2021, FINRA adopted an interim accommodation request process to allow candidates to take additional FINRA exams online, including the Series 24, Series 57, Series 79 and Series 99 exams. Exam candidates seeking to take an exam online based on the interim accommodation request process must complete and submit to FINRA an Online Exam Administration Request Form.
35 See SR-FINRA-2020-027, as extended by SR-FINRA-2020-042, SR-FINRA-2021-006, SR-FINRA-2021-019 and SR-FINRA-2021-031. See also Coronavirus Impact on OHO Hearings.
36 See Coronavirus Impact on Arbitration & Mediation Hearings.
37 See Frequently Asked Questions About Advertising Regulation.
Regulatory Notice
Executive Representative
Alternative Work Arrangements
Remote Offices

redpajama_set_name: RedPajamaCommonCrawl


This set of 2 Golden Harvest Jars would look perfect in your farmhouse kitchen. The larger drinking jar has a brass colored Ball canning jar screw on lid, and the smaller shaker jar appears to have its original brass colored screw on lid.
Both jars are in great vintage condition. No chips or cracks. Sit them in your kitchen window with some fresh flowers or use them at your desk to hold paper clips and push pins. They'd even be great in a sewing space to hold loose pins and needles or to display your buttons!
Another great find! Can't you just picture them filled with paper clips or push pins, sewing needles or buttons, pens or pencils, or even candy! Come see us in our shop and check them out!
Hope you have some excellent weekend plans!


text:
OK — this is just funny:
Posted in accountability, cartoons, Federal Bureau of Investigation, humor, Uncategorized	| Tagged Donald Trump, Hillary Clinton, humor, James Comey, MAGA, Make America Great Again, Mueller report, parody, Robert Mueller, Russian collusion, Superman | Leave a comment
"When you strike at a king…"
"…you better not miss."
Victor Davis Hanson summarizes what we now know about the failed Deep State efforts since 2016 to delegitimize, undermine and remove the duly elected president of the United States. As Hanson notes, "there are many elements to what in time likely will become recognized as the greatest scandal in American political history…"
In candidate and President Trump's case that prepping of the battlefield translated into a coordinated effort among the media, political progressives and celebrities to so demonize Trump that his imminent removal likely would appear a relief to the people. Anything was justified that led to that end.
All through the 2016 campaign and during the first two years of the Trump presidency the media's treatment, according to liberal adjudicators of press coverage, ran about 90 percent negative toward Trump—a landmark bias that continues today.
It's worth noting this demonization efforts extends to Trump's supporters. In its haste to smear Trump and the MAGA movement, the media recently got both the story of the Covington students and a hoax 'hate crime' against a TV star badly wrong. But they wonder why so many Americans are receptive to the charge the corporate news media is "fake news." Hanson continues:
At the same time, liberal attorneys, foundations, Democratic politicians, and progressive activists variously sued to overturn the election on false charges of rigged voting machines. They sought to subvert the Electoral College. They introduced articles of impeachment. They sued to remove Trump under the Emoluments Clause. They attempted to invoke the 25th Amendment. And they even resurrected the ossified Logan Act—before focusing on the appointment of a special counsel to discredit the Trump presidency. Waiting for the 2020 election was seen as too quaint.
During the 2016 election, the Obama Department of Justice warped the Clinton email scandal investigation, from Bill Clinton's secret meeting on an airport tarmac with Attorney General Loretta Lynch, to unethical immunity given to the unveracious Clinton aides Huma Abedin and Cheryl Mills, to James Comey's convoluted predetermined treatment of "likely winner" Clinton, and to DOJ's Bruce Ohr's flagrant conflict of interests in relation to Fusion GPS.
About a dozen FBI and DOJ grandees have now resigned, retired, been fired, or reassigned for unethical and likely illegal behavior—and yet have not faced criminal indictments.
Here's hoping the key word in that last paragraph is "yet."
The Crown Jewel in the coup was the appointment of special counsel Robert Muller to discover supposed 2016 Trump-Russian election collusion. Never has any special investigation been so ill-starred from its conception. Mueller… packed his investigative team with lots of Clinton donors and partisans, some of whom had legally represented Clinton subordinates and even the Clinton Foundation or voiced support for anti-Trump movements…
Mueller's preemptive attacks offered an effective offensive defense for the likely felonious behavior of John Brennan, James Clapper, James Comey, Andrew McCabe, Bruce Ohr, Peter Strzok, and a host of others. While the Mueller lawyers threatened to destroy the lives of bit players like Jerome Corsi, George Papadopoulos, and Roger Stone, they de facto provided exemption to a host of the Washington hierarchy who had lied under oath, obstructed justice, illegally leaked to the press, unmasked and leaked names of surveilled Americans, and misled federal courts under the guise of a "higher loyalty" to the cause of destroying Donald J. Trump.
…sanctimonious arrogant bureaucrats in suits and ties used their government agencies to seek to overturn the 2016 election, abort a presidency, and subvert the U.S. Constitution. And they did all that and more on the premise that they were our moral superiors and had uniquely divine rights to destroy a presidency that they loathed.
And if there's any justice left in this nation, their overreach will result in the destruction of an unelected Deep State apparatus that patriots have come to loathe. I've sensed in recent days the administration may be preparing to finally counterattack this network and pursue these traitors. I pray that is in fact the case. If our Republic is to survive, a very painful and public example must be made. Make the rubble bounce, Mr. President!
Posted in accountability, America First, arrogance, bifactional ruling party, confidence in government, Congress, Constitution, corruption, Deception, Deep State, Department of Justice, Donald Trump, Elections, evil, Federal Bureau of Investigation, freakshows, government obstructions, Homeland Insecurity, institutionalized injustice, media idiocy, MSM idiocy, patriotism, propaganda, rule of law, Russia	| Tagged 25th Amendment, Andrew McCabe, Bruce Ohr, bureaucracy, Cheryl Mills, CIA, Clinton emails, Clinton Foundation, collusion, Covington High School, Deep State, Department of Justice, DOJ, Donald Trump, electoral college, FBI, George Papadopoulos, Hillary Clinton, hoax hate crimes, Huma Abedin, James Clapper, James Comey, Jerome Corsi, John Brennan, MAGA, Peter Strzok, Robert Mueller, Roger Stone, Special Counsel, subversion, treason, Victor Davis Hanson | 1 Comment
Life and death in America
The battle lines are being drawn ever more starkly in this country, between those who believe in the sanctity of life, and those who believe it to be just another disposable commodity.
Pro-abortion activists believe Ruth Bader Ginsburg is their last hope of protecting the travesty known as Roe v. Wade. And perhaps they're right. Interestingly, the "Notorious RBG" hasn't been seen in public in over a month, having missed several oral arguments at the Supreme Court due to health issues (out of character for her). Has anyone done a wellness check on her lately? Some thought Tuesday's State of the Union address might confirm whether she's still an active Supreme Court Justice or we're seeing a Democrat reenactment of the movie "Weekend at Bernie's." But now we're told she'll be skipping it due to a schedule conflict. How… convenient.
Sensing their time is short, abortionists are moving quickly to emplace laws at the State level that would allow the slaughter of the unborn to continue regardless the fate of the Roe precedent. In their haste, they are dropping any pretense this is somehow about making abortion "safe, legal and rare," as the tagline used to go. No, this flurry of activity is about making abortion available on demand at any time, for any reason…
…including just after birth:
Virginia's governor has drawn backlash after suggesting that a pregnancy could be terminated after the baby's birth, as the state debates a bill relaxing restrictions on third trimester abortions. Governor Ralph Northam, a Democrat, made the shocking remarks in an interview with WTOP-FM on Wednesday, as he attempted to explain a Democrat delegate's earlier remarks.
Northam, a pediatric neurologist(!), described a hypothetical situation where a severely deformed newborn infant could be left to die. He said that if a woman were to desire an abortion as she's going into labor, the baby would be delivered and then 'resuscitated if that's what the mother and the family desired, and then a discussion would ensue' between doctors and the mother.
So does this mean that for a period of time after a clump of cells fetus baby leaves the womb and draws breath it is still fair game for abandonment and death? How long is that period? Hours? Days? Weeks? What if an impaired child affects a mother's "mental health" when it reaches two years old? The current crush of new laws go to great lengths to remove criminal penalties for killing an unborn child while assaulting the mother. Activists correctly realized the contradiction in charging "fetal homicide" while still permitting abortion. Their solution is to completely dehumanize the unborn in the eyes of the law, so they only become a "person" when born to a woman who wants them. "Women's rights" do not include being allowed to play God.
We're constantly berated that nobody has the right to tell a woman what to do with her body. But an unborn child is not the woman's body. It is a distinct individual, with its own DNA, fingerprints, and future. Any person's choices are limited by society to the extent they impact others, and this, above all, should be no exception. Aside from rape, every woman exercises her 'choice' in this matter by choosing to abstain from, or engage in, sexual activity. Abortionists like to "what if" all manner of horrific but statistically insignificant scenarios, but the conclusion is inescapable the overwhelming majority of abortions are simply birth control after the fact, at the cost of a human life.
It's only a small step, not a slope, from this point to arguing that any inconvenient life can be terminated. The concept of "assisted suicide" already allows people to end their own life if they find it "too painful." But last year the Netherlands began an investigation into a doctor who allegedly had family hold a patient down while he inserted a fatal IV drip against her will.
I commented recently on the willingness of political opponents now to say things that would have been considered beyond the pale just a generation ago: "Put the MAGA hat kids in the woodchipper," "Burn their school down," and of course an alleged comedian holding a simulated severed head of the president. Add this to the general devaluation of life that abortion and euthanasia represent, and we have an explosive cocktail indeed. Earlier generations of Marxists had no qualms about "breaking a few eggs" in the quest for their socialist paradise. Given the opportunity, I suspect their ideological descendants today would feel the same way.
Still wonder why many of us are determined to protect the right to bear arms? In a culture of death, the means of self-defense are essential.
Do you know what direction your State is headed on this issue? Will it protect the first heartbeat, or enable the murder of a person on the verge of birth? How will you help ensure your State chooses life?
Posted in 2nd Amendment, abortion, Apostasy, Biblical wisdom, Children, choices, Communism, culture, evil, fallen world, parenting, pre-born life, propaganda, Roe v Wade, self-defense, Supreme Court, Uncategorized	| Tagged abortion, assisted suicide, birth control, Connecticut, Democrats, euthanasia, Governor Ralph Northam, MAGA, Marxism, murder, Netherlands, New York, Ralph Northam, Roe v Wade, Ruth Bader Ginsburg, Supreme Court, Tennessee, violent rhetoric, Virginia, Weekend at Bernie's, WTOP, WTOP-FM | Leave a comment
October 4, 2018 by Jemison Thorsby
Why are we buying from China?
It's no secret the U.S. and China are increasingly at odds with each other. China fully recognizes — even embraces — this development, pouring effort into projects like the Confucious Institutes and developing spies among the key staff of important members of Congress. China holds a significant fraction of the U.S. public debt — a potential lever in any showdown, given our nation's reliance on deficit-spending. While we've heard nothing but "Russia, Russia, Russia" since the 2016 presidential election, it's China that poses the most long-term threat to U.S. national security.
And yet, we continue to enable them:
There are two ways for spies to alter the guts of computer equipment. One, known as interdiction, consists of manipulating devices as they're in transit from manufacturer to customer. This approach is favored by U.S. spy agencies, according to documents leaked by former National Security Agency contractor Edward Snowden. The other method involves seeding changes from the very beginning.
One country in particular has an advantage executing this kind of attack: China, which by some estimates makes 75 percent of the world's mobile phones and 90 percent of its PCs…
Supermicro had been an obvious choice to build Elemental's servers. Headquartered north of San Jose's airport, up a smoggy stretch of Interstate 880, the company was founded by Charles Liang, a Taiwanese engineer who attended graduate school in Texas and then moved west to start Supermicro with his wife in 1993. Silicon Valley was then embracing outsourcing, forging a pathway from Taiwanese, and later Chinese, factories to American consumers, and Liang added a comforting advantage: Supermicro's motherboards would be engineered mostly in San Jose, close to the company's biggest clients, even if the products were manufactured overseas.
Today, Supermicro sells more server motherboards than almost anyone else. It also dominates the $1 billion market for boards used in special-purpose computers, from MRI machines to weapons systems. Its motherboards can be found in made-to-order server setups at banks, hedge funds, cloud computing providers, and web-hosting services, among other places. Supermicro has assembly facilities in California, the Netherlands, and Taiwan, but its motherboards—its core product—are nearly all manufactured by contractors in China…
"Think of Supermicro as the Microsoft of the hardware world," says a former U.S. intelligence official who's studied Supermicro and its business model. "Attacking Supermicro motherboards is like attacking Windows. It's like attacking the whole world."
The entire, detailed article, is worth reading. As you do, consider that our government increasingly uses server-enabled cloud computing, even for the most sensitive of information. Does it make sense for our government and military to use hardware produced by our all-but-in-name adversary? What carefully implanted surprises now await us in an actual showdown with this emerging power? Shouldn't our policy be to encourage cost-effective manufacturers here at home?
Over the past 30 years the world became obsessed with obtaining cheap products from China. We're finding out now they may have cost more than we ever suspected.
Make America great again — make America self-reliant, manufacturing its own goods again.
Posted in China, choices, Communism, Debt, defense decline, Deficit, economic disaster, globalism, Homeland Insecurity, Russia, U.S. Intelligence Community, Western decline	| Tagged Admiral Mike Mullen, China, Chinese products, cloud computing, cloud storage, computer servers, computers, Confucious Institute, defense procurement, Deficit, Dianne Feinstein, espionage, intelligence, MAGA, motherboards, National Security Agency, Russia, Senate Intelligence Committee, spying, subterfuge, Supermicro, U.S. debt, U.S. military | Leave a comment
September 1, 2017 by Jemison Thorsby
'Deplorables' get things done
This observation is worth reading in its entirety:
How many flood victims in South Texas have been rescued by the Antifa navy?
Just asking, because on TV this week I've been watching the "Cajun Navy" pull one Dunkirk after another all around the Gulf Coast.
And those good old boys look like they just came off the set of "Duck Dynasty." They could be wearing MAGA hats. Hell, I'll bet one or two of them may have even been falsely accused of committing a fake hate crime or two since the election by some unhinged Social Justice Warrior.
They are, to coin a phrase, deplorables.
Hell, a Chick-fil-A franchise in Houston sent out a power boat to rescue a couple of elderly customers. And the old folks didn't even ask if Chick-fil-A's CEO is still opposed to gay marriage.
Is Michael Moore hosting an All-U-Can-Eat buffet for first responders in Harris County? If he were, surely MSNBC would be covering it, live.
Where are Elizabeth Warren, Whoopi Goldberg, Steven Colbert, etc. etc.?
Seriously, doesn't it look like almost all of the heavy lifting in the wake of Harvey is being done by people who belong to what the Southern Poverty Law Center would describe as "hate groups?"
Speaking of which, when does the [Southern Poverty Law Center's] food drive begin? (((Maybe once they're done transfering all their donations to offshore accounts — Jemison))) Are the non-workers of the Socialist Workers Party and the Spartacist League loading any southbound 18-wheelers with relief supplies this weekend?
Maybe everyone in "the Resistance" is worn out from wearing pink hats and black masks and tipping over statues and sucker punching passers-by with bicycle locks in Berkeley and grabbing an old lady's flag on the Boston Common and burning it — all those wonderful manifestations of how Love Trumps Hate, as they say.
As the Instapundit frequently says, "read the whole thing." There are two groups of people in this land: those who build it up and those who tear it down. The former group is running out of patience with the latter's yapping and worse, while contributing nothing to society. If Antifa hates it so badly here, then get the hell out (I hear the socialist paradise of Venezuela has plenty of openings for violent anarchists right about now). If it's all just a pose, then you're welcome to roll up your sleeves and do something more productive than chanting asinine slogans and showing your historical, political and economic ignorance loudly and violently.
It's getting on the nerves of us busy 'deplorables' who believe in helping our neighbors, not ostracizing them over differences of opinion.
Posted in Church, citizenship, civility, patriotism, preparation, responsibility, social justice fascism, symbolism	| Tagged Antifa, Cajun Navy, Chick-fil-A, Citizen relief efforts, Disaster relief, Houston, Katrina, MAGA, Michael Moore, rescue, self-reliance, Southern Poverty Law Center, SPLC, Trump donation | Leave a comment


The journey to greatness starts with just a step. As a youth who wants to attain a particular milestone in life, there are some crucial steps you have to take. But, you have to start with just a step before you take other necessary steps.
In that your present situation, there is need to take an important bold step. Do not be afraid in any way to do that. All you need is to that bold step which may change your life to better. You may find it difficult to do but the latter Glory will worth it. Yes, you will see the positive results with time.
No matter anything, learn how to separate yourself from the crowd. Taking of the step sometimes may not involve large population of people. Maybe you are waiting for your best friend to take the step with you, it is a personal thing. The road to greatness does not involve large number of people at a time. It's small number at a time.
Let me give you an instance. If you are a marketer marketing for a particular company for instance, there may be need at a particular point in time for you to move from that your particular location that will make you sell more of your products. That is taking a step. But the truth is that not all your colleagues will agree with that your idea.
But because you know that taking the step of leaving that your comfort zone will give you better results, you have to do it. The journey may not be an interesting one but you have to do it because you want to sell. Be driven by passion to get to that level you want to be.
The results of that step you took will come. And when it comes, you will be happy and ready to take other crucial steps. So, do not get rotten in that your state because you don't want to take a step that may get you exposed to the sun. It's better to discomfort yourself today and reap for a longer time.
My advice to you as a youth is this, never be afraid to take that crucial step that is likely to make you. The future positive results worth it. Every rich man in our society today took some bold steps, so, get ready and make that move. No matter the discomfort, look ahead to the glorious days.