This is the last in our series on the FINRA expungement process, and, unfortunately, the future looks grim.
Not only has FINRA made it nearly impossible (in an obvious attempt to curry favor with the public investor bar), but now
This is our second blog on the vanishing FINRA expungement process.
FINRA identifies specific grounds for expungement in FINRA Rule 2080. Rule 2080(b)(1) provided three specific grounds for expungement relief: (1) the claim, allegation or information is factually impossible or
Over the past 20 years, FINRA has made it nearly impossible for brokers to expunge customer complaints and dispute information from their public records. Over the next three blogs, we will discuss the evolution of FINRA’s expungement process and how
FINRA maybe in the process of allowing its examiners to punish member firms for rules’ infractions. See https://www.law360.com/assetmanagement/articles/1143015/finra-wants-to-let-examiners-lower-the-boom-on-brokers?nl_pk=5882ca7d-b76e-42a1-a1fe-eb96fcbcf60f&utm_source=newsletter&utm_medium=email&utm_campaign=assetmanagement. There is no proposed rule as of today. However, such a rule would be a game changer in the sense that examiners,
Although songs and Broadway musicals routinely call upon “memories” as inspiration, it usually is not the province for decisions in FINRA arbitrations. However, we were treated to a memory lesson in what, at first blush, seemed to be a run of the
Way back in 2017, the SEC obtained an emergency asset freeze against an internet-based ICO involving certain Canadian residents, who had raised over $15 million on a variety of social media sites through an alleged fraudulent scheme. http://www.sec.gov/litigation/complaints/2017/comp-pr2017-219.pdf.
At the
Over the last several months, there has been an increase in questions from registered investment advisers relating to using hypothetical performance information. Generally, the use of such information is fraught with danger as well as SEC scrutiny. Not so long ago,
FINRA litigants and arbitrators alike should take note of a federal court’s decision rejecting an unexplained FINRA award when it was unable to discern its basis, notwithstanding that FINRA rules did not require an “explained” decision, and later vacating the
FINRA has published cybersecurity guidance for all its member firms. See https://www.finra.org/sites/default/files/p602363%20Report%20on%20Cybersecurity%20Practices_0.pdf.
In particular, FINRA is indicating that it wants its member firms to bolster their cybersecurity regimes, and limit both internal and external threats. The FINRA report also provides a number
Ever wonder what it’s like to argue in front of the Supremes? Fox partner Ernest E. Badway will moderate a forum with two Supreme Court advocates – Robert G. Heim and Howard Meyers – that will offer a fascinating glimpse
