Posts in FINRA.

Facing an examination or investigation by the Financial Industry and Regulatory Authority (FINRA) can be a stressful and intimidating experience for even the most seasoned financial advisor. Understanding the oversight role FINRA plays and the process can help you to properly prepare and reduce the risk of adverse consequences. If you find yourself the subject of a FINRA inquiry, here are some tips to help you navigate the process:

  1. Determine The Subject Of The Inquiry - If you find yourself involved in an inquiry, FINRA usually will send you a letter requesting information and ...
Posted in: FINRA, OTR, SEC
Reacting in part to recent data-breaches and cyber-attacks on larger retailers, the Financial Industry Regulatory Authority ("FINRA") is conducting a targeted examination of some 20 broker-dealer member firms' compliance and risk-management approaches to cyber-security, aimed at increasing regulators' understanding of the cyber-security risk environment and various approaches and methods used throughout the industry. Wall Street conducted its second comprehensive cyber-security drill, Quantum Dawn 2, just this past July. The after-action study and related ...
Posted in: FINRA, SIFMA
On January 2, 2014, the Financial Industry Regulatory Authority ("FINRA") published its annual regulatory and examination priorities letter for 2014. In the publication, FINRA addressed a number of matters, including suitability of recommendations, addressing issues involving the solicitation, advertising, due diligence and suitability of private placements, and focusing its attention on "recidivist brokers." FINRA has always addressed the issue of suitability. Specifically, FINRA Rule 2111 explains the requirements, which are further explained in Regulatory ...
Posted in: FINRA, SEC

PIABA, the securities-investor plaintiff's bar, issued an October 16th press release roundly criticizing industry self-regulatory rules allowing a broker to seek expungement of a customer-claim from her permanent record. PIABA's release relies on blunt statistics showing that about 60% of arbitration awards containing the word "expungement" granted that relief (with a higher 89-96% rate for awards entered on settlements). The group failed to mention, though, 2009 reforms requiring arbitrators to make an affirmative finding (after a hearing) that:

  • The claim was ...
Posted in: Expungement, FINRA, PIABA

In Regulatory Notice 13-40, FINRA announced that the SEC had approved amendments to its Discovery Guide. The Discovery Guide applies to customer cases (rather than intra-industry cases) and outlines presumptively discoverable documents that the parties to an arbitration should exchange without FINRA or an arbitrator intervening. The amendments concern three areas: (1) electronic discovery, (2) product cases, and (3) affirmations. First, the Discovery Guide was amended to clarify that electronic files are "documents" under the meaning of the Discovery Guide and that ...

Posted in: FINRA
Arbitration is an alternative to the traditional lawsuit filed in court in order to resolve a dispute. It is a formal dispute resolution process in which the parties-customers, brokers, or brokerage firms-select a neutral, third party (or parties) called an arbitrator to decide the matter. In the securities area, the Financial Industry Regulatory Authority, Inc. (FINRA) is a self-regulatory organization and the largest regulator of securities firms doing business with the public. Any arbitration filed that involves securities will likely be filed with FINRA, which then ...
Posted in: FINRA
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