Five-Day Period for Replies to Responses to Motions in Arbitration
An exemption is granted based on the following considerations. First, you have represented that Name, prior to being hired by the Firm, was not engaged in the solicitation of municipal securities business, as defined in the Rule. Second, you have represented that the Firm has a long relationship as an underwriter of municipal securities for the State and State agencies, and neither the hiring of Name nor his Contribution was necessary to obtain municipal securities business from such issuers. Third, the Firm has agreed to institute preventive information barriers to help avoid the potential for conflicting interests to exist and be used, or appear to be used, by the Firm or Name to obtain municipal securities business or compensation or other financial benefits related to such business.
This request for exemptive relief is granted based on the Firms’ representation that the Contribution was made by an employee who does not and has never engaged in the solicitation of municipal securities business, the imposition of certain “information restrictions” and other Firm-wide compliance measures, a Firm- imposed “censure” and compensation restrictions, and the return of the Contribution.
GUIDANCE
Expungement
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Registered Representatives
Senior Management
Affidavits
Arbitration
Central Registration Depository System (CRD® or CRD system)
Customer Dispute Information
Dispute Resolution
Expungement
Rule 2110
Rule 2130
Executive Summary
On
Exemptive relief is granted based on: representations that at the time of the contribution the individual was not employed by the firm and was not an MFP; the firm already had a significant business relationship with the state of whom the contribution recipient is an issuer official (as defined); the firm has instituted information barriers on certain municipal business communications; the individual will be prohibited from the solicitation of certain new municipal business for a period of time.
FINRA Small Firm Advisory Board Election
FINRA Requests Comment on a Proposal to Amend Rule 3110 (Supervision) to Provide Firms the Option to Conduct Remote Inspections of Offices and Locations That Meet Specified Criteria
Summary
The purpose of this Notice is to inform small FINRA member firms1 of the upcoming Small Firm Advisory Committee (SFAC) election. One seat on the SFAC is up for election, representing the New York region.
The SFAC provides guidance to FINRA staff, particularly regarding the potential impact of proposed regulatory initiatives on FINRA’s small firm members. The SFAC meets four times a year
Exemptive relieve is granted based on the following considerations: (1) Firm A took prompt action once it became aware of the Contribution by instituting a self-ban on any Issuer new business solicitation; (2) Firm A sent an electronic reminder to all Firm A and Firm A affiliate employees about Firm A's requirements for pre-clearance of all political contributions; (3) at the time of the Contribution, Name had no personal involvement in soliciting new, or participating in existing, municipal securities business; (4) Firm A has now offered to put in place processes to help ensure the segregation of Issuer information flow, minimizing the potential for quid pro quo resulting from the contribution; and (5) although a less weighty factor, the contribution was returned.
