The paper's aim is to describe a recent increase in FINRA enforcement activity and to discuss how broker‐dealers and representatives may want to prepare themselves for FINRA's increasing willingness to sanction members in the wake of the recent financial crisis.
The paper analyzes FINRA's recent enforcement record, including trends over the past several years in disciplinary actions and fines. It also discusses FINRA's top enforcement issues in 2011; advertising, short selling, auction rate securities, and suitability; and recommends increased compliance efforts in light of FINRA's growing aggressiveness.
It is important that firms and representatives understand how the priorities of this self‐regulatory organization have changed since the financial crisis, fueling this recent growth in FINRA enforcement activity.
The paper offers practical guidance from experienced financial services lawyers.
