On January 23rd, the Fourth Circuit held that UBS Financial and Citigroup must arbitrate the claims brought by a municipal bond issuer whom the banks had advised concerning an offering of auction-rate bonds and the purchasing of interest rate swaps. "Customer," as used by FINRA's mandatory arbitration rule, refers to those who purchase FINRA-regulated services from a FINRA member, namely investment banking and securities business activities. The Court therefore finds that a municipal bond issuer who retained the bond advisory, underwriting, and broker-dealer services of UBS and Citigroup was a customer with whom UBS and Citigroup were required to arbitrate. In addition, the forum selection clause in the parties' broker-dealer agreements was insufficiently specific to supersede FINRA's mandatory arbitration rule. UBS Financial Services, Inc. v. Carilion Clinic.