FINRA’s National Adjudicatory Counsel (“NAC”), recently, affirmed a disciplinary panel decision significantly sanctioning a broker-dealer for paying unregistered persons and entities.  See https://www.finra.org/sites/default/files/2020-07/NAC_2014042606902_Silver-Leaf_062920.pdf.

FINRA alleged, among other things, that a
Continue Reading TRANSACTION-BASED COMPENSATION REQUIRES REGISTRATION . . . PERIOD

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

FINRA has published cybersecurity guidance for all its member firms.  See https://www.finra.org/sites/default/files/p602363%20Report%20on%20Cybersecurity%20Practices_0.pdf.

In particular, FINRA is indicating that it wants its member firms to bolster their cybersecurity regimes, and limit
Continue Reading FINRA Provides Guidance on Cybersecurity for Member Firms