I sometimes (well, perhaps frequently) use this blog as a vehicle to complain about certain things that FINRA does, or about certain of its rules, that I feel are just unfair, plain and simple. To show you that I am not simply making this up, I experienced two such events this past week, which I
Statutory Disqualification
Swing And A Miss: A Rare Form U-4 Loss For FINRA
I have blogged multiple times, as recently as a couple of weeks ago, about the slew of Enforcement actions that FINRA has brought for an RR’s failure to update his or her Form U-4 in a timely manner to disclose a tax lien. My partner, Michael Gross, examines one such case that FINRA managed to…
Statutorily Disqualified? FINRA Says “Deal With It”
It is a nasty thing when one becomes statutorily disqualified. It means either leaving the industry, permanently, or having to file an MC-400 and trying to convince FINRA that you should be permitted to remain in the industry, albeit subject to heightened supervision and extra scrutiny from FINRA. I have previously blogged about statutory disqualification,…
Nobody’s Perfect (And Even FINRA Finally Acknowledged It)
Fans of this blog (or, at least, readers of this blog who are fans of Jeopardy) will no doubt remember Alan’s prior post, published a few weeks ago, and discussing a recent case that FINRA’s Department of Enforcement brought against one of our clients. From the very beginning, we, as her counsel, were both…
U-4 Omissions and Statutory Disqualification: Much Ado About Nothing
I have discussed in prior blogs some issues with the process of registering individuals, and ensuring that information on U-4 is complete and accurate. To some degree, the debate is a bit silly, if the question is whether there is enough information provided on BrokerCheck.
There is a real problem, however, one that is much…