FINRA’s High-Risk Representative Program: Keeping an Eye on Individuals Posing a Heightened Risk of Misconduct

Protecting investors from harm is a top FINRA priority. And when it comes to specific individuals who may pose a risk, FINRA's High Risk Representative (HRR) Program is on the case. 

On this episode, Brooks Brown, Senior Director, and Eric Hebert and John Salerno, Investigative Directors, from the HRR unit join us to explain how they identify and monitor individuals who pose an elevated risk of misconduct to protect investors and maintain the integrity of the market. 

Resources mentioned in this episode:

Episode 114: Bringing Cases Against Individual Brokers

Episode 150: A Cybersecurity Update with FINRA’s Complex Investigations and Intelligence Team (CII)

Key Topic: Protecting Investors from Misconduct

Virtual Conference Panel: Supervision of High-Risk Activities

Listen and subscribe to our podcast on Apple Podcasts, Google Podcasts, Spotify or wherever you listen to your podcasts. Below is a transcript of the episode. Transcripts are generated using a combination of speech recognition software and human editors and may contain errors. Please check the corresponding audio before quoting in print. 

FULL TRANSCRIPT 

00:00 – 00:23 

Kaitlyn Kiernan: Protecting investors from harm is a top FINRA priority. And when it comes to specific individuals who may pose a risk, FINRA's High Risk Representative Program is on the case. On this episode, three members of the High-Risk Rep Program join me to share how they identify and monitor individuals who pose an elevated risk of misconduct to protect investors and maintain the integrity of the market. 

00:23 – 00:32

Intro Music

00:32 – 00:56

Kaitlyn Kiernan: Welcome to FINRA Unscripted. I'm your host, Kaitlyn Kiernan. Today we're going to take a deep dive into FINRA's High Risk Rep Program with three guests from FINRA's National Cause and Financial Crimes Detection Program. Joining me are Brooks Brown, Senior Director of the High-Risk Rep Unit, Eric Hebert and John Salerno, who are both Investigative Directors within the unit. Brooks, John and Eric, thanks for joining me. 

00:56 – 00:57

Brooks Brown: Thank you. 

00:57 – 00:58

Eric Hebert: Glad to be here. 

00:58 – 00:59

John Salerno: Nice to be here. 

00:59 – 01:08

Kaitlyn Kiernan: So, to start off, can you each introduce yourselves and share a little bit about your background and your role within the High-Risk Rep Unit? Brooks, can we start with you? 

01:09 – 01:47

Brooks Brown: I've been with the FINRA High Risk Rep Unit since 2020, and recently the Vulnerable Adults and Seniors Investigations Team joined our collective group in 2022. But prior to joining the group in 2020, I served as the associate district director and prior to that, an examination manager as part of FINRA Atlanta office's firm exam program. So, that was overseeing cycle examinations of member firms for compliance with FINRA rules. Prior to joining FINRA in 2001, I did work for a few years with Trustmark National Bank in Jackson, Mississippi as an equity analyst. 

01:47 – 01:51

Kaitlyn Kiernan: Great. Thanks, Brooks. And Eric, how about you? 

01:51 – 02:25

Eric Hebert: I'm glad to be here, Kaitlyn. I am Eric Hebert, an investigative director in the High-Risk Representative Unit, or as we like to call it, the HRR group. I've been with FINRA for 20 years. My time on the HRR team has been about five years, and prior to that I worked in various roles. I was an examination manager for several years and prior to that, an examiner. And before joining FINRA, I did about three or four years in varying roles in the insurance and brokerage industry, including a role as a securities principal before joining FINRA. 

02:26 – 02:28

Kaitlyn Kiernan: Great, thanks Eric. And John, how about you? 

02:28 – 02:56

John Salerno: Hi, my name is John Salerno. I have been with the High-Risk Rep Program since inception, and I've been with FINRA for a total of just about 22 years. Before joining the HRR department, I was a cause investigator for several years, and before that I was a firm examiner, and before that I worked for Nasdaq as an accountant, all under FINRA's umbrella. And prior to that I worked for different banks in either equity accounting or derivatives accounting. 

02:56 – 03:22

Kaitlyn Kiernan: Great, thanks John. So, a lot of cumulative experience between the three of you at FINRA. Earlier this year, we did have on the podcast Bryan Smith. He joined us to talk about FINRA's Complex Investigations and Intelligence Team focusing on the topic of cybersecurity, but the High-Risk Rep Program is also within CII. Brooks, can you tell us more about this team and why it was created in 2016? 

03:21 –  07:48

Brooks Brown: Sure, Kaitlyn, and I think it's important to mention just at the outset that FINRA has always had a focus on identifying potentially problematic registered representatives. And we have a host of regulatory programs that focus on doing exams and investigations to identify potential misconduct. And when we find it, to address it through imposition of sanctions or bars from FINRA registration. An example of that would be FINRA's Exam Program. They conduct routine exams of firms every four years. FINRA also has its National Cause Program. They have dedicated teams of investigators that do in-depth investigations regarding complaints and reported events that FINRA receives. In addition to that, FINRA has a number of market surveillance teams that do investigations of potential market abuse. And Kaitlyn, as you mentioned, within CII and elsewhere in FINRA, we have specialized teams that do targeted investigations, such as anti-money laundering and fixed income examinations. 

And so, back to your original question, we have a lot of groups over time that have been focused on identifying problematic individuals. But it was around 2014 when FINRA saw a real opportunity to enhance those efforts by using a more data driven approach in an effort to be more proactive in looking for risky representatives. This effort was intended as a complement to the other programs already in place. In other words, in addition to exam efforts and cause investigations that would be triggered over time, FINRA wanted to become more proactive in our approach to identifying risky representatives and then applying investigative resources when it's warranted. So, after that approach was implemented in 2014, we saw benefits from that. We were applying heightened scrutiny to individuals that were proactively identified, mainly due to their history of complaints and disclosures. And at the same time, as we saw those benefits, FINRA saw additional opportunities as technology and analytical abilities were advancing, to implementing a more advanced data modeling approach to identify these representatives. And the idea was, let's also pair that with the creation of a new, dedicated team of investigators who would be responsible for investigating those representatives and for providing support to other groups in FINRA. 

And so, all that culminated in late 2016 with the formation of this dedicated HRR team, and at the same time, we developed tailored investigative review steps to ensure that there was a consistent method and process for these investigations. And we implemented a new machine learning model as a more advanced means of leveraging the data and intelligence that we have at FINRA. And the goal of that model, really, is to learn from the historical profile and characteristics of representatives who are known to have engaged in serious misconduct, and then to apply that knowledge to the entire representative population in order to predict which representatives going forward are most likely to engage in misconduct. 

And suffice it to say, the approach has proven to be successful. There were a significant number of investigations during that early period that resulted in referrals to our Enforcement department with significant findings, and then ultimately, sanctions issued against those representatives. After this early success, we also implemented what we refer to as a monitoring process, which enabled us to have a targeted ability to track incoming information related to individuals that we designate as HRRs. Ultimately, we want to identify those representatives that do the most harm to investors and the markets and help ensure that FINRA is taking action against those individuals if it's warranted. A secondary but a very important aspect of the mission that we have is to bring visibility and attention within FINRA to those individuals that we identify. 

As I mentioned earlier, we have a number of regulatory programs and efforts that are consistently, on an ongoing basis, reviewing different aspects of brokerage firms and representative activities to further our mission of investor protection and market integrity. As they do their work, knowing that a particular representative or group of representatives at a particular firm has been identified as an HRR and presenting escalated risk, that's an important tool in enabling FINRA to really direct its regulatory resources towards the highest risks. So, our group helps provide that visibility.

07:49 – 07:59

Kaitlyn Kiernan: So, we've talked a lot generally about this high-risk population. But what makes a rep high risk? What is FINRA looking at when it's making this determination? 

07:59 – 09:53

Brooks Brown: We have a number of different ways that we do that. As I've already mentioned, when we use a machine learning model and we use it to identify representatives, really at the top portion of that list, so to speak, in terms of what we call their predicted likelihood to engage in future misconduct. And the model does that and ranks those individuals using a number of different factors and attributes that are part of each representative's risk profile, such as complaint disclosures, termination disclosures, financial disclosures, could be associations with risky firms, and it could be their associations with other risky representatives. The machine learning aspect of it views more recent events and associations, and weighs those more heavily than events that occurred many years ago. And so, we use that model and we've made improvements to it over the years to improve its accuracy, whether by adding additional data elements to it or tweaking the machine learning approach. But I think it's important to note we don't just rely on that machine learning model. 

We also use other internal intelligence and interactions with various parts of FINRA to identify other individuals who may be high risk and may warrant a detailed review based on what FINRA is observing, and that information is often just as important and impactful as is output from the machine learning model. We're very mindful of the notion that birds of a feather flock together, and association risk is certainly a significant factor that we look for to identify problematic individuals. But Kaitlyn, at the end of the day, this whole identification process is continuous. It's always ongoing and it's always evolving with market activities. And we approach it in a way that's mindful that we don't want to limit our ability to identify risky individuals or learn about particular representatives that could be emerging as high risk. That's why our relationships with other groups throughout FINRA are so important. 

09:54 – 09:59

Kaitlyn Kiernan: So, if you're best friends with Jordan Belfort, probably not a good sign for you. 

10:00 – 10:02

Brooks Brown: That's a risk indicator. Certainly. 

10:03 – 10:16

Kaitlyn Kiernan: FINRA has about 620,000 registered representatives. So, that's a very big universe. But how big is the overall population we're talking about here when it comes to high-risk reps? 

10:16 – 10:58

Brooks Brown: The number of representatives that we've identified as high risk, it does fluctuate over time, obviously, but the number of individuals that we're talking about here is a small portion of the industry, as one might expect. We're talking about a fraction of a percent. And I think that reflects the reality in the industry that most firms and representatives are out there really trying to do the right thing by investors. And it's important to note that the model that we use to identify potential risky representatives, it reviews the full population of 620,000. We don't target it at particular firms or particular parts of the market. It really is a tool that canvasses the entire population of representatives without bias. 

10:59 – 11:12

Kaitlyn Kiernan: So, when the machine learning model has identified a particular representative as being potentially high risk, John, how does the HRR group review those representatives? 

11:12 - 13:51

John Salerno: So, regardless of how the rep is initially identified, what we're going to always do is conduct a qualitative risk assessment as a means to verify that the RR, or the registered representative, presents an elevated level of risk to the markets, and then to determine what level of additional scrutiny may be warranted. So, after we have identified the individual as a potential high-risk candidate and assigned a high-risk rep analyst, we'll then begin the process of assessing that individual utilizing all data available internally at FINRA, as well as publicly available information. The analyst is looking for significant, tangible items that are linked to that individual that point to material risk or threats. 

So, for example, internal FINRA data will provide useful insights on any related matters such as complaints, tips, Senior Helpline calls, each that are tied directly to the specific individual that we were assessing, as well as any associations with other high-risk representatives or other individuals with a disciplinary history. Then the high-risk rep analyst will also review information from recent FINRA examinations that are tied directly to the individual being assessed, and that includes transaction data that may have been gathered as part of examinations or that were reported by member firms to FINRA elsewhere. And then the high-risk rep analyst will also run a public record search to determine if there is any publicly available information that is not already disclosed on the individual's form U4. 

So, for example, are there any undisclosed criminal actions or outside business activities, or more commonly, undisclosed liens or judgments? And then that public record search can also be used to determine if the individual is living a lifestyle that is overly extravagant or inconsistent with their understood level of income. It is also important to note that the analyst will routinely engage with other internal groups that have touchpoints with the individual to learn additional information, and to understand the status and scope of any recent or ongoing examinations or investigations. This is crucial in determining what we may do next, because the last thing we want to do is open up a new investigation that duplicates a process or ongoing review of that individual. 

Finally, the risk assessment gets formalized into a document that is centrally located and shared with other regulatory groups within FINRA so that everyone understands in a documented fashion, why an individual was selected as a high-risk representative. 

13:51 - 13:59

Kaitlyn Kiernan: So, just because you get filtered out from the machine learning model does not mean you automatically then get tagged as a high-risk rep. 

14:00 - 14:07

John Salerno: That is correct. It requires a secondary qualitative review on top of the model's selection. 

14:07 - 14:11

Kaitlyn Kiernan: And once an individual has been identified as being high risk, what comes next? 

14:12 - 15:14

John Salerno: Then the next step is that we want to approach the representative in a couple of different ways. We can conduct the full investigation of the representatives’ activities, or we can monitor that representative for new events or new incoming intelligence. So, to break that down, one approach is to monitor the representative for those new events and intelligence that we mentioned a moment ago. This involves the review of incoming information such as tips, complaints Form U4 or Form U5 disclosures or other filings, in addition to public record information that we may learn from outside sources. We gather and maintain this information in an internal system that is visible to other regulatory groups within FINRA. On the other hand, the other approach is to open an actual investigation of that individual, which involves a thorough review of the individual's recent activities, using a tailored investigative approach that is consistently applied and specific to that individual that's being investigated. 

15:14 - 15:22

Kaitlyn Kiernan: So, Eric, John just mentioned that tailored investigative approach for the reviews. Can you tell us more about what that entails? 

15:22 - 22:08

Eric Hebert: Our investigators are encouraged to really focus on what presents the most risk to investors and the markets. But in doing so and walking through that process, the first thing we're going to do is reach out and announce the investigation to the representative and the firm that employs them to the extent they are employed. And that's an important outreach, because it provides us the opportunity to have a good dialogue about the nature of our investigation and to field any questions that may come related to it. That often helps us set the investigation off on the right foot and have everybody reasonably apprised of what's to happen. And following the announcement of the investigation is generally a specific records request that is tailored to the individual that's being focused on. As John mentioned, that's generally to complement a very robust effort to surface records that FINRA already has in its possession. Our goal is to not duplicate. Our goal is to be additive in the investigative process, and the investigators who collect that information will aggregate, review and seek to surface where risk is occurring across that period of time, and look for patterns in that information to help form that investigative scope. And it's a highly collaborative process. 

So, importantly, after that investigative scope is formed, we meet. We have what's referred to as a risk identification meeting. We sit down and share intelligence that's been gathered. We bring important collaborative parties to the table, including our Risk Monitoring counterparts. We also have consultative relationships with our Enforcement colleagues, who seek to help us determine which next steps make the most sense, and to be as precise as possible. Once that process is concluded, the investigative scope is nailed down, and then the next set of reviews occur through an assortment of means. So, we may send out 8210 letters that go to the representative, could go to the firm and dig deeper into different areas that will further the investigative scope. Common records that are collected throughout our investigation will include electronic communications. We regularly review communications that are made by registered persons as part of our reviews. Transaction and money moving blotters--we seek to add to intelligence that we have and also further the intelligence with expanded reviews to see exactly what type of trades are occurring, look at money movements specific to customers and representatives to look for conflicts of interest or potential misconduct. 

And a really important record to highlight is the employee file. That helps us understand conflicts of interest and ways those conflicts of interest may be mitigated. And it includes things like loans. Importantly, registered persons can have financial relationships with their employing firm that could present influence on their activities with customers. We want to surface and understand those as much as we can, and another key record would be supervisory records. In collecting information about a representative, it's very important for us to understand the level and extent of the supervision that relates to their activities. It's not uncommon that we may find that an individual we identify as high risk is already subjected to a heightened supervisory plan or some sort of specialized supervision that's used to monitor their activities. Learning about that as early as we can, and understanding the extent of it, helps us scope our investigative plan further and execute it as precisely as we can. 

In terms of the execution of the investigation, you have all these records that we've accumulated and all this analysis that's being performed. But one key step that we take on almost all of our examinations would be to interview representatives, including interviews of their supervisory chain. And what we find is very helpful about that, probably not a surprise, hearing directly from a registered representative is incredibly impactful. It helps explain communication threads. It helps explain customer profiles, certain activities in a meaningful way to get both sides of the story. And in the cases that we have the opportunity to do so, we will go on site to conduct those interviews, which also enables us to be in the location where the registered person conducts their business. There's direct opportunity to observe their interface with those electronic applications, including the systems that they use to transact securities, communication methods that they use and the like. And then talking to the supervisor provides that additional perspective. Meeting with the person in charge of that representative affords the opportunity to address observations that we have, and to get a richer understanding of any mitigation that may occur. 

When our investigative process does surface misconduct, we intend to address it comprehensively. That can include more formalized steps. Some of those may include outreach to customers. Some of those outreaches will be to individuals who have not complained. Also, we may take on the record testimony of certain individuals and potentially supervisors as a means to fully address misconduct that we're seeing and to ensure that we are interpreting it properly. Going to the collaborative process that I discussed earlier, all of that is done with a high degree of communication across departments and most specifically and when warranted, any more pronounced and formal steps that we may take in an investigation are done in a highly collaborative fashion with our Enforcement counterparts. And as we near those conclusions, it's important to note that we don't have an expectation of a certain outcome on these investigations. I often describe it as an intentional journey. We want to get to the right conclusion, and a conclusion that is not resulting in action is no less than one that is. 

For the benefit of the audience, I was going to surface a couple things that we may see on investigations, particularly those that are most relevant to some recent years of reviews, and one that I would highlight would be communication issues. You've probably read a lot about off-channel communications and understand the issues that extend from it, but I would also highlight conflicts of interest. I think a broad stroke is important here. When individuals have relationships with their customers that extend beyond the day-to-day operation of the broker-dealer, there may be activities that are away from the broker-dealer. That's an area where there can be problems. 

22:09 - 22:24

Kaitlyn Kiernan: Eric talked a little bit about some of the areas the investigations turn up, issues like off-channel communications on disclosed conflicts of interest. But John, can you talk about the types of issues and misconduct that the team has identified over the years? 

22:25 - 23:39

John Salerno: Sure, gladly. So, over the years, our investigations have historically covered a broad range of activities and misconduct. Common findings are excessive trading or an undisclosed business activity, or what is known as selling away, which is basically selling securities without the knowledge or approval of your broker-dealer. Depending on the time frame, suitability is a common finding, which is now replaced with regulation best interest and the care obligation. And then oftentimes we'll see anti-money laundering concerns or know your customer issues where the customers aren't adequately known as to who these people are and what their intentions are. Another very common finding is a violation of Rule 8210. 

Rule 8210 essentially requires representatives to cooperate with FINRA's investigation. Oftentimes, if we've touched on something very significant, perhaps something with underlying misconduct that could be criminal, the representatives just won't cooperate with the investigation. If you don't cooperate with an investigation, then you could be sanctioned on the Rule 8210 and typically would be barred for failure to cooperate. So, those are the common findings that we generally have had. That's not all encompassing, but that's generally where they land. 

23:40 - 24:08

Kaitlyn Kiernan: And we have a number of podcasts with our Enforcement team that touch on some things, like excessive trading and when FINRA pursues enforcement action against individual brokers that we'll link to in our show notes if anyone wants to follow up with a listen of those. But are there any recent success stories that highlight the impact of your work that you can share? 

24:08 - 27:37

John Salerno: Certainly, one rep that comes to mind who was selected to be on the high-risk monitoring program due to issues concerning their prior sales practice activities. While that person was selected and was being monitored, FINRA received a call on the Senior Helpline complaint from a 90-year-old investor. That allegation was that this individual was sold investments that were not suitable for them. So, considering the person was already being monitored by the High-Risk Rep Program, and now we have a complaint coming in from a 90-year-old investor that's sort of fits the profile of why they were selected in the first place. So, what we did in that situation is we escalated the representative to a full investigation, and that means looking at their entire book of business. Who are they making sales to? Are the sales suitable? Do they make sense for this investor? And the outcome of that investigation was that we had found that the representative was, in fact, making unsuitable recommendations. 

In this particular instance, it was approximately five senior investors, all of whom the investments weren't suitable for them. This one particular case resulted in disgorgement of $38,000. It had to be paid back. It actually went to a full hearing. And the hearing panel decision was that the representative had not only made unsuitable recommendations, but also did so to customers that were elderly investors and highly at risk. And ultimately, what happened was the broker was barred for the misconduct based upon the hearing panel's decision. I would add there was one other finding from the hearing panel, and that was that the representative in question didn't fully understand what he was selling, which is a violation of the rules also. You can't make a good faith solicitation or a recommendation if you don't understand the product yourself. 

A second example, we also have cases sometimes that are focused more on more serious misconduct, where when I say more serious straight conversion cases, we had a case where we had selected someone to be a high-risk representative. That person fit the profile of being a recidivist, seems to always have some kind of issue with their sales practice that's being investigated by regulators, and we had one representative years ago that had fit that profile, was on monitoring, and then eventually was subject to an investigation. And during the investigation, we received a referral from Adult Protective Services saying that there were some indications that the representative was pressuring an elderly investor to send money to the broker, and where the money was going to didn't seem to make sense. 

So, we did look into this more carefully and tried to understand what was happening with this elderly investor's funds. And what we were able to learn was that the investor was convinced to take money out of his brokerage account to make an investment away from the broker-dealer, and then ultimately, the investor didn't want to make the investment, and then the investor was not directed to send the money back to his brokerage account. Instead, he was being pressured into sending the money to a third-party account. That third-party account was in the account held in the name of the broker. In that case, we were able to establish that the customer's funds had in fact been converted and then misused. The case did go to hearing. Interestingly, the representative did not appear for the hearing, so it resulted in a default decision and a finding of fact that the funds were in fact converted. 

27:38 – 27:46

Kaitlyn Kiernan: What can you share with our listeners about some of the issues and activity that the HRR group has been tackling more recently? 

27:47 - 28:10

John Salerno: More recently, we're always looking at Reg BI. Oftentimes Eric and I, we're both looking into things that relate to pump and dump scenarios. So, it really runs the gamut. We're also looking into a lot of manipulative trading activity. We still see AML issues coming up. Excessive trading is still an issue that does seem to come around. Those are some common ones. 

28:11 - 32:00

Eric Hebert: And I think this speaks to the breadth of our program to highlight a market centric focus. I'd like to talk a little bit about underwriting activities that we have looked at through individuals. I first want to highlight Regulatory Notice 22-25. It does an excellent job of providing the backdrop of some of the issues that FINRA has seen. But to simplify this, you have a large and evolving marketplace in relation to just the amount of investors that are out there, and it presents a lot of opportunities, but it can also present a lot of risks. And as the Notice highlights, there are increased risks when there are inherent boundaries to what a broker-dealer can learn and understand about issuers and customers. 

As an underwriter, if an issuer is residing in the U.S. and subjected to U.S. regulations, a lot of what you're going to get is very predictable. You know the standards and the regulations are uniform, but when you do venture out and you are involved with other foreign parties to engage in selling activities, that's when there can be inherent boundaries, differences that require some degree of pause and thinking about any customized analysis or risk measures that need to be taken. And in the underwriting realm, that becomes particularly important because you're bringing securities to market, you're providing opportunity for people all across the world to invest in a security. And where we've seen issues, candidly, are just where those gaps in understanding or understanding of customers manifest into activities that appear inherently suspicious. 

On that point, we have observed the surroundings of those engagements to have similar gaps in mitigation for how the sales process occurs and ultimately the underwriting. Things like off-channel communications have been observed, where these are very complicated dealings with individuals all across the world. The ability to see, understand, translate those communications can be very challenging, particularly if those communications are not known to the member firm at the time in which they're occurring. You then also see conflicts of interest form in relation to how shares are allocated. When shares are allocated in large quantities to single entities, that can present potential liquidity constraints and other issues that may be exploited in the aftermarket. And then you look at the ins and outs of the customer relationships. In some cases, to the extent that individuals reside outside of the US, the ability to ascertain complete profile information, to authenticate identification, to ensure that there's an understanding of any nomination relationships that may exist related to it, is key because between the issuer and the customers, the underwriter is going to have a real important obligation to fully understand, at a minimum, those parts of the equation when considering its role as an underwriter. 

And when there are gaps, when there are those issues, there can be activities that occur in the aftermarket that may appear to be conflicts of interest that have been played upon, or where activities related to the investors appear to be contradicting their initial intent. And this is an evolving area of review for FINRA. This is an area where FINRA sees an important focus and has utilized multiple programs, including the HRR group, to really surface issues, fully understand them, and inform a variety of things, not just including the Regulatory Notice that I spoke of earlier. 

32:01 - 32:11

Kaitlyn Kiernan: Thanks, Eric. And to wrap up, I think it's clear how the HRR program benefits investors. But, Brooks, how do you think the program benefits the industry at large? 

32:12 - 33:18

Brooks Brown: FINRA having specialized teams in its regulatory programs that focus on different aspects of the industry and really focusing on either emerging risk or areas of high risk, and that could be cybersecurity, could be cryptocurrencies, and digital assets could be money laundering. In this case, it's a focus on representatives that we believe present elevated risk just by virtue of what we know about them and based on their behaviors. All those things help make the US securities market a safer place for investors to be, to invest their hard-earned money. And I think that has a real, tangible benefit to the industry at large in that regard, in terms of member firms being able to serve their customers effectively and attract new customers. 

And the last thing I would say there, Kaitlyn, is the vast majority of our registered firms and representatives are out there doing the right thing by their customers. And I think that any victories that we're achieving and holding individual brokers accountable when they engage in this sort of misconduct and when they hurt investors or the markets, that's a win for the rest of the representatives in the industry who are doing things the right way. 

33:19 - 33:47

Kaitlyn Kiernan: Great. Well, that's it for today's episode of FINRA Unscripted. Brooks, Eric and John, thank you for joining me to highlight the work of the High-Risk Rep Unit and how you are working to protect investors and the reputation of the industry. Listeners, if you don't already, be sure to subscribe to FINRA Unscripted wherever you listen to podcasts to stay up to date on all of our latest episodes. Today's episode was produced by me, Kaitlyn Kiernan, coordinated by Hannah Krobock and edited and engineered by John Williams. Until next time. 

33:47 – 33:53

Outro Music

33:53 - 34:26

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