Two New FINRA Rules For The Protection Of Senior Investors

by Carlton Fields

Carlton Fields

The protection of senior investors continues to be a priority for FINRA, from both an examination and enforcement perspective. In fact, FINRA detailed how seniors are one of its major areas of concern in the last three editions of its Annual Regulatory and Examination Priorities Letter.

Certain rules changes that took effect February 5, 2018 have equipped FINRA members with new tools to protect senior and other vulnerable investors from financial exploitation. First, members may now place temporary holds on disbursements from accounts when they reasonably believe that financial exploitation has occurred, is occurring, or has been, or will be, attempted. Second, members must now solicit a trusted contact person for each retail customer account, and they may contact that person to address possible financial exploitation.

This article discusses the new rules and provides insight on how members might expect the rules to impact examinations, enforcement actions, and customer claims.

FINRA’s Role in Protecting Senior Investors

Many constituencies play a role in protecting senior investors, including: investors’ relatives, friends, and advisors; members and their associated persons; law enforcement; federal and state regulatory agencies; and FINRA. As detailed below, FINRA’s role in detecting and preventing the exploitation of senior investors has three principal components.

First, FINRA detects and deters bad actors in the securities industry through: review of customer complaints, tips, and trade data; routine and cause examinations; and enforcement of its rules and certain federal securities laws. FINRA’s use of enforcement actions to protect senior investors has focused, in large part, on the suitability of recommended investment products, particularly, complex and high-yield products. These matters have focused on whether investment recommendations were suitable given a senior investor’s financial profile, including his or her age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, and risk tolerance. The poor judgment of one registered representative becomes a significant problem for the firm when FINRA inquires into the rep’s recommendations, and the firm’s supervision and training to detect and prevent the rep’s improper sales practices.

Second, FINRA gathers and publicizes information on senior investors, both to protect them, and to educate its members and their associated persons. Its Securities Helpline for Seniors is a powerful resource for senior investors and their advocates. The Helpline allows FINRA to collect information on potential issues with members and registered representatives, as well as industry trends, and then raise awareness about particular issues and schemes, including through Investor Alerts and other publications. These have included, in the last two years, those schemes that have targeted senior and other vulnerable investors with speculative energy-based investments, non-traded REITs, and, most recently, cryptocurrency stock scams.

Third, FINRA has encouraged and, with the new rules, empowered members to act to protect their senior and other vulnerable customers from financial exploitation. Consider a registered representative who suspects that a senior investor has fallen under the improper influence of a long-lost niece or a new accountant and who has now requested an outbound transfer of funds or securities to the suspected exploiter. The new rules concern this third role for FINRA, and the rules encourage – if not conscript – members to detect and prevent financial exploitation in real time.

Temporary Holds on Disbursements: New FINRA Rule 2165

FINRA Rule 2165 applies to “Specified Adult(s),” which is defined as both “a natural person age 65 and older,” and an adult of any age “who the member reasonably believes has a mental or physical impairment that renders the individual unable to protect his or her own interests.” R. 2165(a)(1). This definition follows the definition of similar terms in financial elder abuse in many state codes, in that it includes not just investors of a certain age (here, 65), but also adults of any age with a particular impairment. The Rule does not take the further restrictive step that some states have enacted in limiting elder abuse to instances where the victim is over a statutory age and is actually suffering from infirmities of aging, such as demonstrated mental dysfunction.

The Rule permits – but does not require – members to place a temporary hold on disbursement of funds or securities from the account of a Specified Adult if the member “reasonably believes that financial exploitation of the Specified Adult has occurred, is occurring, has been attempted, or will be attempted.” R. 2165(b)(1)(A). The Rule does not permit members to place a temporary hold on the purchase or sale of securities in an account; it only covers disbursements.

To place a hold on disbursements, members must take two further steps: (i) within two business days after placing the hold, notify all authorized parties to the account and the Trusted Contact Person (explained below), unless the member reasonably believes one of those persons has engaged in the exploitation; and (ii) “immediately initiate[] an internal review of the facts and circumstances” of the suspected financial exploitation. R. 2165(b)(1)(B) & (C).

Time frames on the hold are tight. The hold expires “not later than 15 business days” after first being placed, unless the “internal review” supports an additional extension of no longer than 10 business days. R. 2165(b)(2) & (3). The hold may be extended by a state regulator or agency, as well as a court. R. 2165(b)((2) & (3). Although the terms “state regulator or agency” are undefined, they presumably include state law enforcement and adult protective services, as these agencies are often the first responders in cases of suspected financial elder abuse.

Members that implement a temporary hold must have written supervisory procedures (“WSPs”) reasonably designed to achieve compliance with the Rule, including procedures related to the identification, escalation, and reporting of matters related to the financial exploitation of Specified Adults. The WSPs also must identify the title of each person authorized to place, terminate, or extend a temporary hold. The Rule further requires that such persons be associated persons of the member who serve in a supervisory, compliance, or legal capacity. Members that use the Rule also must develop and document training policies and programs reasonably designed to ensure compliance with the Rule.

The Rule also imposes recordkeeping requirements on members who implement it, including the maintenance of records regarding: (i) the subject disbursement requests; (ii) the finding of a reasonable belief of financial exploitation underlying the decision to place the temporary hold; (iii) the name and title of the person who authorized the hold; (iv) evidence of notification of the hold to the requisite persons; and (v) the aforementioned internal review.

Apart from its direct authorization for such a hold, the Rule provides members and their associated persons who follow it with a “safe harbor” from other FINRA rules, specifically, Rule 2010 (the “catch all” provision for unethical conduct); Rule 2150 (barring “improper use” of customer’s securities or funds); and, perhaps most importantly, Rule 11870 (requiring members to “expedite” certain customer requests to transfer securities).

Trusted Contact Person: Amendments to FINRA Rule 4512

FINRA Rule 4512 specifies what customer account information members must maintain for each account. The amendment to Rule 4512 adds section (a)(1)(F), requiring, for non-institutional accounts, the maintenance of information of “a trusted contact person age 18 or older who may be contacted about the customer’s account.” By its terms, this amendment is not limited to aged or otherwise impaired customers. If the customer or prospective customer fails to identify such a contact person, members may still open the account if they have made “reasonable efforts to obtain the name of and contact information for a trusted contact person.” R. 4512.06

Members are required to disclose, in writing at the time of account opening, that they may contact the trusted person if they suspect financial exploitation:

[T]he member or an associated person of the member is authorized to contact the trusted contact person and disclose information about the customer’s account to address possible financial exploitation, to confirm the specifics of the customer’s current contact information, health status, or the identity of any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise permitted by Rule 2165. Supp. Mat. 4512.06.

Members need not seek to obtain trusted-contact information for existing accounts until they update the information for the accounts, either in the course of their routine business or as otherwise required by applicable laws and rules. The innovation of this Rule is that members now have an avenue to discuss account information with a customer’s trusted third party without violating any privacy laws.

Examination and Enforcement of the Rule Changes

Sophisticated members have been focused on protecting senior investors for some time. Some larger members even have units dedicated to handling seniors issues. But even for them, these rules changes require new infrastructure, policies, procedures, and training. Members have for the last year or so – since at least the SEC’s approvals of the rules changes in February 2017 – been developing these procedures and processes, and further educating employees and partners on elder abuse and how to implement the new requirements.

The near-term focus of examinations will likely be on members’ development of WSPs to achieve compliance with the temporary-hold rule, and on whether members have established recordkeeping procedures and training programs reasonably designed to ensure that associated persons comply with both rules changes.

On January 8, 2018, FINRA pushed its Annual Regulatory and Examination Priorities Letter. Like last year, FINRA focused its discussion of elder abuse on enforcement against intentional bad actors in the industry rather than on firms that fail to implement or properly empower registered representatives to detect third-party fraud. Accordingly, enforcement for “missed opportunities” to detect third-party fraud may be the subject of examinations for the near to medium-term. The Letter notes new Rule 2165 and the amendment to Rule 4512, describing them as “tools to protect senior investors from these types of schemes.” Further, FINRA “remind[ed] firms of their obligation to file a Suspicious Activity Report (SAR) for illicit activity involving the exploitation of senior investors.”

These temporary holds and the ability to call a trusted contact person are significant additional tools that FINRA likely is expecting members to actually use. Members should think carefully about potential liability in enforcement actions and customer arbitrations for financial exploitation that reasonably could and should have been detected and prevented using these new tools or otherwise. In this respect, note that while Supplemental Material 2165.01 clarifies that the Rule “does not require members to place temporary holds on disbursement of funds or securities . . . .” (emphasis added), members will, in essence, be required to implement such holds. That is, if there are warning signs of financial exploitation, members need to take action. There is no safe harbor from customers’ lawyers asserting claims that members failed to place a temporary hold, as they were permitted to do and should have done.

There likewise is no safe harbor from customers’ lawyers asserting claims that members wrongfully placed a temporary hold. Therefore, members should follow the Rule, and follow it carefully. Documentation of the implementation of the new Rules will be important to defend against customer objections and complaints to a hold. As noted above, record retention is specified in the Rule. Further, because the hold will be at the direction of an associated person who “serves in a supervisor, compliance or legal capacity for the member,” 2165(c)(2), standardization of records practices should be easier than if the hold could be initiated at the level of customer interaction only.

Members may also want to reexamine whether and how to investigate, verify, and then document suspicions of abuse of senior investors. “Reasonable belief” to support such a hold may be based on “the facts and circumstances observed in the member’s business relationship with the natural person.” Supplementary Material 2165.03. While the Rule contemplates that this “reasonable belief” can be documented at the time of the decision to initiate the hold (see R. 2165(d)), often suspicion arises outside the context of a request for disbursement of funds or securities. This could include the addition of an authorized person to an account, or comments from, or abnormal behavior by, a senior during a regular phone call or meeting. How to capture this information, and what to do about it then, rather than just when a disbursement has been requested, should be a part of the planning.

It is expected that elder abuse will continue to grow as both an unfortunate practice and as an enforcement priority, as the number and percentage of investors continue to age, particularly, with the ongoing retirements of the “Baby Boomer” generation. How much action FINRA and other regulators will require to detect and prevent financial exploitation of senior and other vulnerable investors remains to be seen. Benjamin Franklin’s famous quote that “an ounce of prevention is worth a pound of cure” rings true in addressing matters of possible financial exploitation.


The two new FINRA rules changes encourage well-meaning members and their associated persons to take proactive steps to protect their senior and other vulnerable customers from financial exploitation. FINRA’s examination and enforcement likely will focus on the procedural, training, compliance, and recordkeeping requirements attendant to the new rules.

Michael A. Gross, a former senior attorney at FINRA, represents broker-dealers, investment advisors, and registered persons as a partner at Ulmer & Berne LLP’s Boca Raton, Florida, office. This article was drafted in conjunction with an ABA Regional CLE Workshop, “Current Issues in FINRA Arbitration and Enforcement,” held February 9, 2018, in Tampa, Florida. The workshop was co-sponsored by the Securities Litigation Committee and the Alternative Dispute Resolution Committee of the Section of Litigation.

Originally published in the American Bar Association's Securities Litigation Journal. Republished with permission from the American Bar Association.


Written by:

Carlton Fields

Carlton Fields on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.