Benjamin Coulter

Benjamin Coulter

Burr & Forman

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SEC Approved FINRA Public Arbitrator Rule

On February 26, 2015, the Securities and Exchange Commission (“SEC”) approved a rule proposed by the Financial Industry Regulatory Authority, Inc. (“FINRA”). The rule, originally proposed by FINRA on June 17, 2014, amends...more

3/10/2015 - Arbitration FINRA New Regulations Public Arbitrators SEC

FINRA Sends “Public Arbitrators” Rule to SEC for Approval

On June 30, 2014, the Financial Industry Regulatory Authority (“FINRA”) sent its proposed rules to limit the definition of “public arbitrators” to those without any experience in the securities industry. Previously, an...more

7/23/2014 - Arbitration Arbitrators Compliance FINRA SEC

Reverse Churning: Don't Fall Asleep at the Wheel

It is obvious that broker-dealers and their registered representatives, and investment advisors, must be careful in making recommendations to clients. But the recent increase in regulatory interest relating to inaction in a...more

7/11/2014 - Broker-Dealer Fiduciary Duty FINRA Investment Adviser Reverse Churning SEC

FINRA Withdraws Bonus Disclosure Rule

On Friday, June 20, 2014, the Financial Industry Regulatory Authority (“FINRA”) withdrew its proposed Rule 2243, which would have required disclosure and reporting of FINRA member recruiting practices. Essentially, the rule...more

7/2/2014 - Bonuses Disclosure Requirements FINRA Proposed Regulation

SEC Begins Proceedings on FINRA Proposal Concerning Per Share Estimated Valuations for Unlisted DPP and REIT Securities

On May 20, 2014, the Securities and Exchange Commission initiated proceedings to determine whether to approve a proposal by the Financial Industry Regulatory Authority, Inc, (FINRA) to amend the NASD and FINRA rules governing...more

6/13/2014 - Compliance DPPs FINRA NASD REIT SEC

FINRA Sends Transition Bonus Disclosure Rule To SEC

In a move designed to increase transparency between its member firms’ registered persons (“representatives”) and their former clients when they move from one firm to another, the Financial Industry Regulatory Authority...more

5/21/2014 - Compliance Disclosure Requirements FINRA SEC Transparency

FINRA Finalizes Mandatory Background Check Rule

On April 24, 2014, the Financial Industry Regulatory Authority (FINRA) announced that its board of governors had approved rules requiring that firms to run background checks on new hires, whether new brokers or transfers, to...more

5/14/2014 - Background Checks Compliance Criminal Background Checks FINRA

FINRA Moves Forward With Proposed Rule Requiring Disclosure Of Recruitment Bonuses

FINRA has submitted a proposal to the SEC to adopt FINRA Rule 2243 (Disclosure and Reporting Obligations Related to Recruitment Practices). In FINRA’s words, Rule 2243 would require, in some cases, “specific disclosure by...more

4/3/2014 - Bonuses Corporate Bonuses Disclosure Requirements FINRA

Burr Alert: Proposed FINRA Rules Governing Markups, Commissions And Fees

Through its recent Regulatory Notice 13-07, the Financial Industry Regulatory Authority ("FINRA") announced and sought comments on its proposed amendments to rules governing markups, markdowns, commissions and fees associated...more

4/10/2013 - Broker Commissions Brokers Fees FINRA Markups

Burr Alert: FINRA Amends Subpoena And Arbitrator Order Rules

In its recent Regulatory Notice 13-04, the Financial Industry Regulatory Authority ("FINRA") announced amendments to its Customer and Industry Codes of Arbitration Procedure related to subpoenas and arbitrator orders for the...more

3/27/2013 - Arbitration Discovery Document Productions FINRA Subpoenas

Burr Alert: FINRA Updates Guidance On Its Suitability Rule

In its Regulatory Notice 12-55, the Financial Industry Regulatory Authority ("FINRA") has updated its guidance on FINRA Rule 2111 concerning suitability. This is FINRA's fourth regulatory notice concerning the rule -- it...more

12/19/2012 - Broker-Dealer FINRA Investment Adviser Suitability Rule

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