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
FINRA
LPL AWC Proves, Once Again, That Big Firms Can Buy Their Way Out Of Trouble That Would Kill Small Firms
By UB Greensfelder on
LPL may be the biggest BD in the country, with 21,500 reps operating out of almost 13,000 branch offices. Heaven knows how much money it brings in every year, but, goodness, it must be a lot. And good thing, too, given how much the firm keeps paying to FINRA in fines for its serial, repeated,…
Another Fine Churning Mess
By UB Greensfelder on
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…
What If FINRA Held An Election And Nobody Came?
By UB Greensfelder on
Not too long ago, I posted a blog complaining that FINRA’s Nominating Committee had basically abdicated its responsibility to identify suitable candidates for certain seats on FINRA’s Board. Perhaps not surprisingly, I never heard – from anyone, but least of all FINRA itself – why the Nominating Committee had punted. But, I put my head…
FINRA’s SD Proposal Is Smart. Let’s Hope It’s Just The Start
By UB Greensfelder on
Posted in FINRA, Statutory Disqualification
There is a little corner of the FINRA world that most people never have the need or desire to visit, and that’s the not-so-quaint village of statutory disqualification. SD, for short. I have written about this sad place many times, mostly about those poor souls who manage to end up here through confusion, or, too…
Let’s Hear It For CCOs; After All, They Are Human People
By UB Greensfelder on
We have frequently blogged here about the degree of attention that regulators pay to Chief Compliance Officers, and whether it is proper that they sometimes are named individually in Enforcement actions. And we are hardly the only ones who see this issue. The New York City Bar back in February – I know, that seems…
How NOT To Supervise For Churning
By UB Greensfelder on
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…
FINRA AWC Provides New Defense To Allegation Of “Willfulness”
By UB Greensfelder on
I dare you. In fact, I double-dog dare you to figure out how or why FINRA decides to charge willfulness in some cases but not in others. Bottom line is that it is nearly impossible (except if you’re a big firm, in which case you can rest easy that FINRA will manage to skip the…
The Trouble With Texts
By UB Greensfelder on
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…
FINRA Is About To Make It MUCH Harder To Obtain Expungement – Part Two
By Chris Seps on
Here is the second part of Chris’s blog on FINRA’s effort to make expungement harder and more expensive to obtain. It is remarkable to me just how blatant FINRA has been here in admitting the reasons for the rule amendments. Anyone who thinks that FINRA is a membership organization that actually cares for its members…