The Financial Industry Regulatory Authority, Inc. (“FINRA”) has been quite clear on its views of “nontraditional exchange traded products,” such as leveraged inverse exchange-traded notes (“ETNs”) and exchange-traded funds (“ETFs”). Because these products have features such as inverse leverage and daily resets, FINRA views these products as unsuitable for retail investors who plan to hold them for more than one trading session, particularly in volatile markets.1 Consequently, when member firms or their personnel fail to heed this advice, such as when selling these products to retail investors, allowing those investors to hold these in their accounts for extended periods of time and failing to supervise, or failing to enforce written supervisory procedures intended to prohibit such sales, FINRA has taken action. In a recent trio of cases, similar sets of facts brought FINRA enforcement