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Broker-Dealer Law Corner Blog

Articles: 1-10 of 83

FINRA Plays Guessing Game With Expungement Waiver Request

USA - September 24 2018 When a registered rep contacts us about seeking expungement of customer complaints from his or her CRD record, we always respond that expungement is…

FINRA Proposes To Require Disclosure Of Insurance Information In Arbitrations. Seriously.

USA - July 26 2018 Once upon a time, FINRA at least pretended that it was interested in maintaining a level playing field for claimants and Respondents in the…

FINRA’s “Massive” Discovery Failure Results In…Absolutely Nothing

USA - July 9 2018 You 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…

Has The SEC Taken All The Mystery Out Of Filing SARs?

USA - July 5 2018 This week, Charles Schwab consented to pay the SEC a $2.8 million civil penalty for failing to file SARs on certain transactions - suspicious…

PIABA’s Efforts To Get A Law Passed To Ensure Payment Of Legal Fees Off To Rough Start

USA - June 28 2018 About a month ago, I posted a blog about the apparent success that PIABA had achieved in getting two US senators — a Democrat and a Republican — to…

FINRA’s Attempt To Change Well-Established Federal Law On Churning

USA - May 7 2018 FINRA has been busy lately issuing Reg Notices on proposed changes to its Rules. Several of the proposed changes seek to give FINRA more discretion…

FINRA Knows Best - At Least According To FINRA - When It Comes To Hiring Decisions

USA - May 4 2018 I don’t know how many times I’ve written about FINRA’s efforts over the years to address “rogue brokers,” or what it refers to nowadays more…

Reverse-Churning: BDs Are Damned If They Do, And Damned If They Don’t

USA - April 10 2018 A couple of years ago, I blogged about the concept of “reverse churning,” i.e., putting a customer who trades only infrequently into a fee-based…

Do FINRA’s Proposed MAP Rules Put PIABA’s Concern Over Money Ahead Of Fairness To Members?

USA - March 26 2018 I have often used this forum to complain about FINRA’s lack of backbone when it comes to dealing with PIABA, the group of lawyers who represent…

What Not To Wear (Or Do) At Your FINRA OTR

USA - March 20 2018 I recently sat in on a panel of senior attorneys from FINRA Enforcement and while they did not actually discuss wardrobe selection, they did give some…