disciplinary action

I have always operated with the understanding that, per FINRA rules, one cannot supervise him- or herself.  Hardly an outrageous proposition.  Today, however, that fundamental, bedrock understanding was so shaken, it has left me wondering whether anything is what it seems (especially when coupled with Loyola’s win this weekend over Illinois, which, really, can only

My friend and former colleague, Brian Rubin, publishes annually his analysis of FINRA Enforcement cases, spotting trends in terms of the number and types of matters it brings, the sanctions meted out, etc.  It is an excellent tool, and eagerly anticipated by lots of us who practice in this industry.  One of the hard parts

Historically, one of the surest ways to get yourself permanently barred from the industry is to forge a customer’s signature on something.  According to the pertinent Sanction Guideline, at a minimum, a forgery, that is, a true forgery – a signature that is neither authorized nor subsequently ratified by the customer – should result in

I apologize for taking so long between posts, but, to be fair, there’s been a lot going on in the past week or so that has captured my attention!  I wish everyone a happy and SAFE new year! – Alan

While undoubtedly FINRA will be issuing its annual “examination priorities” letter any day now, that

Having completed my Enforcement hearing conducted by Zoom – more about that in an upcoming post – I can finally turn my attention back to some matters that arose while I was busy.

One that stood out for the sheer (and frightening) universality of its lesson is an SEC settlement entered into by Jonestrading Institutional

Right after I posted this, FINRA announced a third AML settlement, this time with Interactive Brokers.  It was no small deal: it came with a $15 million fine and an obligation to retain an independent consultant.  (In addition to the FINRA AWC, Interactive simultaneously entered into settlements with the SEC — with another $11.5

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