About a month ago, the SEC announced a settlement in a modest little case that has, nevertheless, managed to garner a lot of attention. This is a result of the fact that one of the respondents was the CCO, i.e.,
Broker- Dealer Law Corner
Blog Authors
Latest from Broker- Dealer Law Corner
Equitable’s Settlement With The SEC Demonstrates That A Single Customer Complaint Can Serve As Notice Of A Systemic Issue
Last week I posted a blog about the dangers of not heeding findings made during a regulatory exam, at least findings of clear, undisputable compliance issues that cannot be meaningfully defended. Today I am writing to highlight a corollary rule:…
Barclays AWC Teaches Important Lessons About The Price To Pay For Not Heeding Exam Findings
There is no question in my mind that the quality of FINRA examiners is a bit uneven. Some are smart and insightful and helpful; others are, well, not. Most of the time, they do know what they’re talking about. That…
When It Comes To GPB, FINRA Looks At Things Quite Differently Than The SEC And The DOJ
Among the criticisms I have leveled against FINRA are (1) that it is increasingly acting like a claimant’s arbitration attorney, by taking every possible opportunity to blame member firms for losses incurred by investors when other palpable reasons for those…
The 411 On FINRA Rule 4111
Well, Memorial Day is just past us, so we all know what that means: it’s time for FINRA to conduct its first annual assessment of its member firms to determine whether they should be branded a “Restricted” firm under new…
FINRA’s Fixation On Unpaid Arbitration Awards Has Morphed Into Something More Dangerous
Shortly, I hope to get around to drafting a blog post about FINRA’s latest demonstration of abasement to PIABA and claimants’ counsel everywhere, namely new Rule 4111. But, that rule is such a monstrosity that it will take a little…
More Thoughts On The Age Of FINRA Arbitrators
Not too long ago, I wrote a piece complaining about (among other things) the fact that the potential arbitrators that FINRA rolled out to the parties in a particular arbitration I was handling skewed juuuuuuust a bit towards the older…
Some Ideas In Response To FINRA’s Recent “Discussion Paper” On Expungement
FINRA recently published a “Discussion Paper” on expungement of customer dispute information in which it outlines its plans going forward on revising the expungement process. Expungement_Discussion_Paper.pdf (finra.org) (Let me just start by applauding FINRA for trying hard to get this…
Highlights From SIFMA’s Compliance And Legal Seminar 2022
Thanks to Chris for not only making the personal sacrifice of traveling from frigid Chicago to sunny Florida to attend the SIFMA Compliance and Legal conference last week, but for providing these helpful comments about the sessions he attended. –…
Lack Of Diversity In FINRA Arbitration Panels, Or, How Many Old, White Guys Does It Take To Hear A Case?
Let me say at the outset that I, myself, am an old (by most people’s definition, anyway), white man. So, selfishly, I’ve got nothing against old, white men. But, the fact is that FINRA arbitration panels are disproportionately populated by…