Is an Anagram of "Wells Notice" Okay?

I'm thinking "swell notice" might be somewhere in my manual, or "client lowse"? Colleen's wit"? Or maybe "elite clowns"? Will one of these do?

What I am referring to is this: in last week's FINRA news release and attached Letter of AWC FINRA states that Goldman Sachs failed to include the term “Wells notice” in its procedures manual.  As far as I can discern, there is no rule or specific guidance calling for this exact terminology. So I'm wondering if FINRA examiners will accept a substitute...an anagram (ha ha) or perhaps something reasonable (I'm being serious now), like procedures requiring Reps to promptly inform firms of necessary changes to U4, including any new 'yes' answers on U4 disclosure questions. That--the latter--is what most firms probably have in their manuals. But let's assume that is not enough. Uh, given the whopping $650,000 fine imposed on Goldman, I think it's safe to assume that is not enough.

Okay, to be fair, I will note that the fine was also assessed for GS's failure to update its Reps' U4s to disclose the actual on-going SEC investigations that were made known to Reps via, yes, Wells notices. So there is some substance behind the action.

My point here? Check your procedures to see if they include the phrase "Wells notice" and an explicit requirement that registered persons immediately inform you of any investigations they are subjected to.  You can then sort out whether or not such an investigation merits reporting on U4 (see Question 14G(2)).


Many thanks to Andy's Anagram Solver for online assistance.