On February 10th, the Fourth Circuit addressed an issue regarding arbitration procedure and held that an appeal on the issue of arbitrability divests the district court of jurisdiction over the underlying claims and requires a stay of the action, unless the district court certifies the appeal as frivolous or forfeited. It then addressed the merits of the pending case, in which plaintiff alleged defendants violated the Investment Advisers Act. The Court held that the arbitration clause in the parties' advisory contract applied to any dispute between the parties, including those accruing before the contract. Levin v. Alms and Associates, Inc.