On July 22, the SEC approved amendments to FINRA Rule 2081 that prohibit member firms from conditioning arbitration settlements (or seeking to) upon a customer’s assent to CRD expungement relief. The Rule amendments prohibit paying any consideration or compensation for expungement relief and apply even if a customer suggests such a bargain. SEC Rel. No. 34-72649 (July 22, 2014). In cases that may warrant expungement relief under the conditions specified in Rule 2081, SIFMA’s comment letter suggested, and FINRA responded approvingly to, using settlement-agreement language reciting that: (1) Respondents intend to seek expungement relief; (2) expungement relief was not a condition of the settlement; (3) Respondents have not paid any consideration related to expungement; and (4) the Claimant may participate in expungement proceedings as (s)he chooses. We addressed FINRA’s Rule proposal earlier this year in, “FINRA Moves to Make Expungement Independent” (May 14, 2014).