As should be clear to readers of this Blog, I find that Enforcement actions often provide the best guidance in terms of what regulators deem to be unacceptable conduct, which is very useful when dealing with subjective standards like “reasonableness.” This past week, FINRA published an AWC submitted by Coastal Equities, Inc. that offers a
Rule 3110
When It Comes To Sanctions, What Does “Relevant Disciplinary History” Mean To FINRA, And Does It Vary Depending On The Size Of The Firm?
By Alan Wolper on
The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a $1.4 million fine. Their offense? They each violated FINRA’s supervisory rules because for a number of years, dating…
FINRA Is Going Rogue…Again
By Alan Wolper on
I read an article this week bemoaning the fact that “rogue brokers” – a term that is commonly used but steadfastly undefined – apparently remain rampant in the securities industry. Anyone that has read FINRA’s 2017 Exam Priorities Letter knows that this is one of the issues on which FINRA intends to focus its regulatory…
FINRA’s (Mostly) New Background Check Rule Goes Into Effect July 1
By Alan Wolper on
As everyone who studies FINRA’s Regulatory Notices is already well aware, two days from now, FINRA’s rule requiring background checks on prospective registered representatives goes into effect. A lot of what the new rule mandates is not new, but, as there are some things that clearly were not required before, it is worth taking a…
FINRA’s Hiring Requirements Under Rule 3110: Don’t Trust and Verify
By Alan Wolper on
FINRA Rule 3110 is the new supervision rule, of course, replacing old NASD Rule 3010. Most of it became effective on December 1, 2014, but, certain parts will only become effective on July 1, 2015. One of the latter sections is 3110(e), which addresses a firm’s obligation to investigate anyone being considered for registration, and…