After having proudly served for decades, and surviving a dramatic face-lift in 2012 (when old NASD Rule 2310 was replaced by shiny new FINRA Rule 2111), it seems that the “suitability rule,” as we’ve come to know it, has, at long last, been quietly sent out to pasture by FINRA. Although the title of Reg
FINRA
What Do You Call A Nominating Committee That Doesn’t Actually Nominate Anyone? A FINRA Nominating Committee
By Alan Wolper on
This will be a quick one, but I just had to get something off my chest before the weekend. As you probably know, there is an election upcoming. No, not that one, the one to elect certain members of FINRA’s Board of Governors. That Board consists of 24 members, as follows:
- Robert Cook, who is
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A Modest Proposal On The Appropriate Allocation Of Fees In Expungement Cases
By Chris Seps on
A couple of years ago, I complained about PIABA’s effort to make expungement even more difficult to obtain. Well, fast forward to June 1, and, as Chris Seps explains here, the SEC has approved the first proposed expungement rule change from FINRA, one that appears to serve no purpose other than to generate money for…
For FINRA, Restitution Is The Solution
By Alan Wolper on
Seems like just days ago I blogged about Jessica Hopper and her commitment to providing restitution to customers. Since I posted that blog, there were two other settlements (which I added to that blog as updates) in which FINRA again seemed to prioritize restitution over the imposition of a fine. Yesterday, however, FINRA announced a…
FINRA’s New MAP Rules Put Customers’ Interests Ahead Of Everything, Including Logic
By Alan Wolper on
Two years ago, when it was just an ugly rule proposal, I blogged about FINRA’s intent to modify its MAP rules to “Incentivize Payment of Arbitration Awards.” Sadly, FINRA once again showed it spinelessness by pushing these rule amendments through, ignoring the concerns of its own member firms. They are now not just rule proposals,…
Securities Regulators In The Age Of Covid-19
By Blaine Doyle on
Thanks to Blaine not only for attending this conference, but for actually listening, so he could share with you the insights he gleaned from the local securities regulators here in Chicago. – Alan
While much of the broker-dealer world has been trying to figure out how to protect the financial welfare of their customers, in…
The Trouble With The “Should-Have-Known” Standard, As It Applies To Red Flags
By Alan Wolper on
Last year, I wrote a piece called “Wedbush Learns That It’s Not Enough Just To Spot Red Flags.” As the title suggests, it analyzed an SEC decision in which Wedbush was sanctioned because it failed in several respects to follow up on certain red flags it saw that were indicative of potential misconduct.
I am…
SunTrust Settlement Proves That Jessica Hopper, FINRA’s Head Of Enforcement, Would Be A Good Umpire
By Alan Wolper on
I may have said this before in another post, but in my opinion, whether a baseball umpire is good or bad is not a matter of whether he has a low strikezone, a high strikezone, or a wide one. What matters is that whatever that umpire deems to be a strike vs. a ball is…
FINRA Addresses Online Fraud In The Face Of COVID-19
By Fran Goins on
I am fairly certain that at least every once in a while, you appreciate hearing from someone a bit less snarky than me. If so, then you’re in luck! Please enjoy this post from my partner, and my co-leader of Ulmer’s Financial Services practice group, Fran Goins, about FINRA’s response to COVID-19. – Alan
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FINRA’s Concerns About Maintaining Confidentiality Seem To Be Broadening
By Alan Wolper on
I hope that, by now, everyone understands and appreciates just how freakishly sensitive the regulators are to misconduct involving the wrongful sharing of confidential information. If you don’t, however, FINRA was kind enough to publish two settlements in the last few weeks that work well to drive this concept home. And both share an interesting…