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[Webinar] FINRA: A Look Back at 2023 and What’s In Store for 2024 - December 19th, 12:00 pm - 1:00 pm EST

Join Ulmer partner Alan M. Wolper as he addresses hot topics including FINRA's oversight of Reg BI, trends in enforcement and arbitration filings, and perspective whether FINRA would survive a constitutional challenge....more

[Webinar] FINRA 2022: What to Expect - March 10th, 2:00 pm - 3:00 pm EST

Join Ulmer partners Alan M. Wolper and Heidi E. VonderHeide as they address hot topics, including recent rule proposals, exam priorities, and other FINRA developments....more

When It Comes To Sanctions, What Does “Relevant Disciplinary History” Mean To FINRA, And Does It Vary Depending On The Size Of The...

The day after Christmas, FINRA issued a press release announcing that five big firms – Citigroup, J.P. Morgan Chase, LPL, Morgan Stanley and Merrill Lynch – had each entered into a settlement, collectively agreeing to pay a...more

An Undisclosed Conflict Of Interest – By FINRA – Results In Bar Being Vacated

From time to time, I have lamented that FINRA does not hold itself to the same lofty standards to which it holds its members. I realize I am painting with a broad brush, as there are lots of folks at FINRA who do a great job,...more

FINRA’s Secret Power To Control Information

In the past week, I ran across two discrete instances in which FINRA acts as a secret gatekeeper of sorts, exercising its own subjective judgment, without anyone knowing what, exactly, it is doing or why, employing...more

FINRA Proposes To Dispense With Due Process, All Because It’s Failed To Do Its Job Of Policing The Markets

Reading Reg Notice 19-17 makes me think of the legal arguments that I’ve recently read regarding whether a president can be found guilty of obstructing justice if the actions in question were taken out in the open, for...more

FINRA’s Proposal On High-Risk Firms Is A Must-Read, But Hardly A Must-Enjoy

I apologize for all the posts this week, but I am traveling and am in a different time zone, so I am awake at hours when, ordinarily, I would be asleep, giving me time to muse. Anyway, given that, I will not test your...more

FINRA Says, Proof? We Don’t Need Your Stinkin’ Proof

If you are a regular reader of this blog, then you know that over my last few posts, I have been talking about an increasingly visible effort by FINRA to turn its regulatory eye from rogue brokers – who have been an irritant...more

FINRA Is Going After “High-Risk” Firms, But First Has To Invent The Definition Of High-Risk

I told you two weeks ago in my blog post that this would happen. I told you that when Robert Cook announced the topics to be taken up at the February/March FINRA Board meeting in Boca Raton, he slipped and used the new phrase...more

FINRA Coins A Scary New Term: “High-Risk Firms”

On February 26, 2019, FINRA sent a seemingly innocuous memo to member firms giving a brief outline of the subjects that its Board will take up at its meeting this week in sunny Boca Raton, Florida. (Wait, the Board isn’t...more

The Securities Regulators All Have Senior-itis. Maybe For Good Reason.

The securities industry’s concern over the aging of the U.S. population, specifically, aging investors, has, apparently, reached a fever pitch. On February 5th in New York, SIFMA hosted its “Senior Investor Protection...more

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