On February 22nd, the Fourth Circuit affirmed an order vacating an arbitration panel's award to registered representatives terminated by their employer, a broker-dealer. Although the award was ostensibly for wrongful termination, the panel based its findings on breaches of fiduciary duty arising out of the broker-dealer's legal representation of itself and plaintiffs in a third party arbitration. As such, the panel improperly adjudicated a tort claim, not an arbitrable employment claim, and in doing so, exceeded its authority under the Federal Arbitration Act. Raymond James Financial Services, Inc. v. Bishop.