The Audit Committee of the FINRA Board of Governors engaged Lowenstein Sandler LLP to conduct an independent review in connection with a Fulton County, Georgia Superior Court decision vacating an arbitration award in favor of respondent Wells Fargo Clearing Services, LLC. The Court of Appeals of Georgia reversed the Fulton County, Georgia Superior Court decision finding no evidence of an agreement between Wells Fargo and FINRA. Furthermore, the Court of Appeals of Georgia found nothing that indicated Wells Fargo manipulated the arbitrator pool in the subject arbitration.
A clearing member may use negative response letters to assign orphan accounts to an introducing broker-dealer on the clearing member’s platform.
Dear Ms. Dyer:
I am responding to your letter dated March 10, 2023, as supplemented by conversations with the staff, in which you seek interpretive guidance regarding the use of negative response letters by National Financial Services LLC (“NFS”) to
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Students, individuals considering a securities-industry career, and
A member firm may include related performance information in institutional communications concerning Section 3(c)(1) Funds, subject to the stated conditions discussed in the letter.
A member may use negative response letters to effect a bulk transfer of employee equity compensation plan accounts, as directed by an employer.
