If you’ve read this blog for even a short while, you know my feelings on Rule 8210, or, more specifically, how FINRA uses that rule, i.e., as a cudgel to keep member firms and their associated persons in line. Endless 8210 requests for documents and information, sometimes asking multiple times for the same stuff, each… Continue Reading
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BD Learns It’s Not Enough To Have A Supervisory Procedure For OBAs, You Actually Have To Follow It
Posted in Enforcement, FINRA, Outside business activities, Rule 3270, UncategorizedIn most Enforcement cases involving outside business activities, it is the registered rep who is named as the respondent, and the allegation is that the RR failed to provide notice (or timely notice) to his or her broker-dealer about the OBA. On occasion, however, it is the BD that gets tripped up, typically for not… Continue Reading
FINRA’s “Massive” Discovery Failure Results In…Absolutely Nothing
Posted in Disciplinary Process, Enforcement, FINRA, Sanctions, UncategorizedYou are not going to believe this one. Here are the unadulterated facts, taken directly from the Order entered by the FINRA Hearing Officer (an Order, by the way, which FINRA elected not to publish on its website): Five days into an Enforcement hearing against Respondent Steven Larson, “Enforcement disclosed that it just realized it… Continue Reading
What Else Is New? FINRA Skates Despite “Massive” Failure To Produce Documents
Posted in Discovery, Enforcement, FINRA, Rule 8210, Rule 9251, UncategorizedLet’s play pretend. Can you imagine what FINRA would do to a respondent broker-dealer in an Enforcement action that announced on Day Five of the hearing – i.e., during the “final phase” of the hearing – that – whoops! – it had forgotten to produce certain documents that it should have produced eight months before… Continue Reading
FINRA’s New Rules On Seniors: Let’s Protect Them From Their Own Bad Decisions?
Posted in FINRA, Rule 2165, Rule 4512, Senior Investors, UncategorizedWe have written before about senior investors, but I saw a couple of things in the last couple of weeks that suggests this subject needs to be revisited. First, back in February, the SEC got around to passing FINRA’s proposed rules to protect senior investors, including both new Rule 2165 and amendments to existing Rule… Continue Reading
FINRA Board Election: A Real Choice For a Change in the Mid-Size Firm Board Seat
Posted in Board of Governors, Elections, FINRA, UncategorizedI have told many people over the years that the only way to effect true change at FINRA must come from the inside. I can write blog posts every day pointing out what I perceive to be the occasional error of FINRA’s ways, but apart from the cathartic effect it provides me to vent, the… Continue Reading
David Slays Goliath: Texas Investment Advisor Beats SEC In Administrative Proceeding
Posted in Disciplinary Process, SEC, UncategorizedIf you have been a regular reader of this Blog, or even if you just browse the Wall Street Journal on occasion, you have undoubtedly noticed the attention being given over the last few weeks to the SEC’s decision increasingly to bring its Enforcement cases before Administrative Law Judges, rather than in federal court. While… Continue Reading
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