In what has become a yearly occurrence, FINRA has notified its member firms about its intent regarding the member firms’ compliance programs.  See https://www.finra.org/rules-guidance/guidance/reports/2021-finras-examination-and-risk-monitoring-program.

This year, FINRA combined its Report
Continue Reading FINRA’s New Guidance Report… the Name Did Not Change To Protect the Innocent

Let’s be honest, the only people usually concerned about business continuity plans (“BCP”) are compliance folks and the lawyers.  In fact, many probably have not looked at their BCP since
Continue Reading Coronavirus Reaches Pandemic Status: You Better Pull Out the Old Business Continuity Plan

FINRA maybe in the process of allowing its examiners to punish member firms for rules’ infractions.  See  https://www.law360.com/assetmanagement/articles/1143015/finra-wants-to-let-examiners-lower-the-boom-on-brokers?nl_pk=5882ca7d-b76e-42a1-a1fe-eb96fcbcf60f&utm_source=newsletter&utm_medium=email&utm_campaign=assetmanagement.  There is no proposed rule as of today.  However, such a rule
Continue Reading FINRA Maybe Making It Easier for Examiners to Deliver Hurt to Member Firms

FINRA litigants and arbitrators alike should take note of a federal court’s decision rejecting an unexplained FINRA award when it was unable to discern its basis, notwithstanding that FINRA rules
Continue Reading Federal Court’s Remand and Rejection of ‘Inscrutable’ FINRA Award Has Broad Implications