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Call for Vacatur of Massachusetts’ Fiduciary Duty Standard for Broker/Dealers

On August 25, 2023, Justice Wendlandt of the Massachusetts Supreme Judicial Court issued a ruling in Robinhood Financial, LLC v. Secretary of the Commonwealth which upheld the legality of the fiduciary duty standard imposed...more

Implications of FINRA’s Recently Released 2022 Sanction Guidelines

FINRA’s recent overhaul of its Sanction Guidelines is the largest and most significant in two, if not three, decades. It would be quite the understatement to say that the time had come for FINRA to make a much-needed change...more

Observations from a Review of FINRA’s 2021 Sanction Guidelines

Key Takeaways: ..FINRA released its most recent Sanctions Guideline, effective immediately, on October 20, 2021. A link to that document can be found here. ..The key change in the 2021 Sanctions Guideline is a new...more

The Song Remains the Same - FINRA’s Riff on High-Risk Brokers and Firms

Key Takeaways: ..On September 28, 2021, FINRA released Regulatory Notice 21-34 which introduces additional new rules aimed at addressing high risk or “recidivist” brokers and the member firms that hire them.  ..Under...more

September 1st Implementation of FINRA Rule 1017(a)(7)

Recap of FINRA Rule 1017(a)(7) - If you recall from our May 11th alert, effective September 1, 2021, FINRA Rule 1017(a)(7) will require a member firm to file a CMA when a natural person seeks to become an owner, control...more

FINRA Warns of Potential Regulatory Exposure Stemming From Overreaching Pre-dispute Arbitration Agreements

Key Takeaways: ..With pre-dispute arbitration agreements constantly under attack by PIABA and various federal legislators, FINRA recently issued Regulatory Notice 21-16 to address member firm agreements that extend too...more

Through the Issuance of New Rules Aimed at Recidivist Brokers and the Firms That Hire Them, FINRA Loudly Exclaims to its...

Key Takeaways:  ..After years of warning firms of the need for enhanced diligence in retaining or hiring brokers with a significant history of misconduct, FINRA has adopted new rules to address such brokers. ..As set...more

U.S. COVID-19: “The Show Must Go On!” Court Rejects Challenge to FINRA’s Virtual-Hearing Procedure

As courts around the country navigate how to handle proceedings during the COVID-19 pandemic, arbitral tribunals face the same struggles. The Financial Industry Regulatory Authority (“FINRA”) operates the largest arbitral...more

One Month In: Top 5 Takeaways for U.S. Securities Firms in the Midst of the Pandemic

U.S. Securities firms are on the frontlines of one of the most volatile economic periods in history. With the Dow Jones Industrial Average flirting with the 30,000 mark in February, few firms could have predicted that the...more

Losing Control: Proposed FINRA Amendment Eliminates Control as an Element for Proving an Excessive Trading Violation

KEY TAKEAWAYS - ..A proposed amendment to FINRA Rule 2111 eliminates the requirement for FINRA to prove the broker exercised “control” over the customer's account to establish excessive trading. ..FINRA acknowledges...more

FINRA Explores Options Aimed at Encouraging the Payment of Arbitration Awards and Settlements

Key Takeaways - ..While typically there is a relatively small portion of FINRA customer cases that proceed to an award of damages, approximately one out of every four damage awards goes unpaid. ..FINRA has proposed...more

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