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Registered Representatives Enforcement Actions

Holland & Knight LLP

Twinkle-Twinkle Little SAR: SEC & FINRA Settle with Broker-Dealers and Registered Rep

Holland & Knight LLP on

In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more

UB Greensfelder LLP

You Should Understand The Difference Between Violating A Firm Policy And Violating A FINRA Rule . . . Even If FINRA Doesn’t

UB Greensfelder LLP on

FINRA, of course, has lots, and lots, of rules. Heck, it has rules about making rules. The things that RRs can and cannot do per those rules are strictly proscribed, mostly in great detail. Things that ordinary people can...more

UB Greensfelder LLP

FINRA AWC Provides New Defense To Allegation Of “Willfulness”

UB Greensfelder LLP on

I dare you. In fact, I double-dog dare you to figure out how or why FINRA decides to charge willfulness in some cases but not in others. Bottom line is that it is nearly impossible (except if you’re a big firm, in which case...more

Fox Rothschild LLP

Transaction-Based Compensation Requires Registration . . . Period

Fox Rothschild LLP on

FINRA’s National Adjudicatory Counsel (“NAC”), recently, affirmed a disciplinary panel decision significantly sanctioning a broker-dealer for paying unregistered persons and entities. FINRA alleged, among other things,...more

UB Greensfelder LLP

It Is Not Possible To Predict When FINRA Will Charge Something As Willful. Or Is It?

UB Greensfelder LLP on

I have written a few times about FINRA’s ceaseless interest in bringing cases against registered reps who fail to update their Form U-4 in a timely manner to disclose the fact that a tax lien has been filed against them. Or...more

UB Greensfelder LLP

Wedbush Learns That It’s Not Enough Just To Spot Red Flags

UB Greensfelder LLP on

I have been busy the last month getting ready for a big arbitration, and attending the first week of what looks like is going to be a four- or five-week slog when all is said and done. So, I am just catching up on some recent...more

King & Spalding

FINRA Incentivizes Member Firms to Self-Report and Remediate 529 Plan Deficiencies

King & Spalding on

On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more

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