An irreverent Wall Street Blog
by Bill Singer
 
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Written: October 30, 2014

As with virtually every job, the practice of law often becomes mind-numbingly boring. Every so often, however, the profession presents you with a fascinating puzzle. A recent federal case may strike some as a religious question raising basic issues of moral right and wrong -- a question of "sin," if you will. For others, these same set of facts do not present any issue of morality but a complex and complicated question of law and its interpretation. Consider the New York State Domestic Relations Law:

Section 5: A marriage is incestuous and void whether the relatives are legitimate or illegitimate between either:
1. An ancestor and a descendant;
2. A brother and sister of either the whole or the half blood;
3. An uncle and niece or an aunt or nephew.
If a marriage prohibited by the foregoing provisions of this section be solemnized it shall be void, and the parties thereto shall each be fined not less than fifty nor more than one hundred dollars and may, in the discretion of the court in addition to said fine, be imprisoned for a term not exceeding six months. Any person who shall knowingly and wilfully solemnize such marriage, or procure or aid in the solemnization of the same, shall be deemed guilty of a misdemeanor and shall be fined or imprisoned in like manner.

Keeping in mind the incest proscriptions of Section 5, factor in the following:

A Conditional Permanent Resident

Huyen Nguyen, a citizen of Vietnam,  was granted conditional permanent resident status in the United States of America in 2000.  In January of 2000, in Rochester, NY, Nguyen, then 19, married naturalized American citizen Vu Trong, 24.

The Wife's Grandmother Was Her Husband's Mother

Funny thing about husband Trong and wife Nguyen. In 1950, Nguyen's grandmother Nguyen Thi Ba, gave birth to Nguyen's mother. In 1975, grandmother Ba gave birth to Nguyen's husband Trong but by a different father than that of Nguyen's mother.

Yeah, go ahead, ponder that!

As a result of Ba’s parenting, Nguyen’s mother was Trong’s half-sister, and Nguyen winds up as her husband’s half-niece and he her half-uncle.

Under NY Domestic Relations Law Section, Section 5(2) says "half" brothers and sisters can't marry and under 5(3) uncles and nieces can't marry. So . . . what about a marriage between a half-niece and her half-uncle?

Immigration Steps In

Remember that part where Nguyen became a conditional legal resident of the US by marriage? On July 10, 2002, Nguyen and her husband filed a joint petition to remove the conditions but on December 12, 2007, the United States Customs and Immigration Service denied the petition after finding that Nguyen was Truong’s half‐niece. That familial relationship apparently was deemed incestuous and voided the marriage; and, accordingly, an immigration judge ordered Nguyen's removed from the country. On appeal, the Board of Immigration Appeals affirmed the removal order.

How Do You See It?

Nguyen petitioned the United States Court of Appeals for the Second Circuit, which submitted the following question of for certification to the New York State Court of Appeals:

"Does section 5 (3) of New York's Domestic Relations Law void as incestuous a marriage between an uncle and niece 'of the half blood' (that is, where the husband is the half-brother of the wife's mother)?"

In finding that the marriage between a half-uncle and half-niece was not void as incestuous under section 5(3), the NY Court of Appeals offered the following rationale in a concurring opinion:

I also conclude that the apparent purpose of section 5 (3) supports a reading that excludes half-uncle/half-niece marriages from its scope. Section 5 as a whole may be thought of as serving two purposes: it reflects long-held and deeply-rooted values, and it is also concerned with preventing genetic diseases and defects. Sections 5 (1) and 5 (2), prohibiting primarily parent-child and brother-sister marriages, are grounded in the almost universal horror with which such marriages are viewed – a horror perhaps attributable to the destructive effect on normal family life that would follow if people viewed their parents, children, brothers and sisters as potential sexual partners. As the Appellate Division explained in Matter of May (280 App Div 647, 649 [3d Dept 1952], aff'd 305 NY 486 [1953]), these relationships are "so incestuous in degree as to have been regarded with abhorrence since time immemorial."

Pages 5-6 of the Opinion

The Opinion further explains:

The second purpose of section 5's prohibition of incest is to prevent the increased risk of genetic disorders generally believed to result from "inbreeding." (It may be no coincidence that the broadening of the incest statute in 1893 was roughly contemporaneous with the development of the modern science of genetics in the late 19th century.) We are not geneticists, and the record and the briefs in this case do not contain any scientific analysis; but neither party disputes the intuitively correct-seeming conclusion that the genetic risk in a half-uncle, half-niece relationship is half what it would be if the parties were related by the full blood. Indeed, both parties acknowledged at oral argument that the risk in a half-uncle/half-niece marriage is comparable to the risk in a marriage of first cousins. First cousins are allowed to marry in New York, and I conclude that it was not the Legislature's purpose to avert the similar, relatively small, genetic risk inherent in relationships like this one.

Pages 6-7 of the Opinion

READ the Full-Text Opinions:


 

Written: October 29, 2014

When it comes to in-house compliance and industry regulatory matters, a loan is a loan and a gift is a gift -- and the two have very different meanings and consequences. As BrokeAndBroker Blog has often reported, Wall Street regulators take a dim view of stockbrokers borrowing from their clients and there are specific rules, regulations, and policies against that practice. On the other hand, gifts often fall into a gray area of something that's not necessarily illegal or prohibited by a regulator but may very well be proscribed in your firm's in-house Written Supervisory Procedures or Employee Handbook. In today's blog we have a case involving both gifts and loans. And an elderly client. And a stockbroker's wife. And some evasion and non-cooperation.

Case In Point

For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority (“FINRA”), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, James Gregory Nixon submitted a Letter of Acceptance, Waiver and Consent (“AWC”), which FINRA accepted. In the Matter of James Gregory Nixon, Respondent (AWC  2014041097901, October 15, 2014).

Nixon was first registered in 2007 and during the relevant period of October 2012 through April 2014, he was associated with FINRA member firm J.P. Morgan Securities, LLC.

Ask And You Shall Receive . . . a gift

The AWC alleges that sometime in January 2012, Nixon asked an elderly client of his at J.P. Morgan Securities for a $5,000 loan. The client purportedly opted to give the sum to Nixon as a gift rather than in the form of the requested loan. At the time of this transaction, Nixon was purportedly aware that his firm prohibited the receipt of loans or cash gift from customers by registered representatives. Moreover, Nixon failed to disclose the gift or get his firm’s approval to accept same.

Ask And You Shall Receive . . . a loan

Around October 11, 2013, Nixon asked the elderly client for another $5,000 loan, which this time the customer agreed to extend in that form.  In accordance with the terms of the loan, Nixon purportedly executed an unsecured promissory note calling for monthly payments of $300.  The AWC asserts that Nixon made only $450 in payments.  The AWC alleges that Nixon failed to notify J.P. Morgan Securities, LLC of the loan or get his firm’s approval to accept same.

Stop Asking Already

In February 2014, the AWC asserts that Nixon again asked his elderly client for a loan of unspecified value but was refused. 

A Different Helping Hand

Finally, in October 2012, the AWC alleges that Nixon received a $2,000 gift from another firm customer; however, he again failed to report the cash gift or get his firm’s approval. 
In October 2012, Nixon falsely stated on J.P. Morgan Securities’ Annual Certification Form that he had not received any cash gifts from customers for the reporting period.  

Compliance Asks Nixon

Sometime in February 2014, J.P. Morgan Securities’ Central Supervision Unit flagged an email from the customer who had extended the $2,000 gift in October 2012.  That email appears to have given the impression that the customer's gift was a loan – additionally, the AWC suggests that the email's sender seemed to have entertained a second loan request from Nixon. In the customer’s email to Nixon, the AWC alleges that the customer 

suggested in the email that Nixon and “AN” discuss their “financial predicament” with someone. The context of the message implied that “AB” was Nixon’s spouse. . .

SIDE BAR: FINRA’s written statement is that the customer suggested that Nixon and AN discuss something; however, we are then informed that AB is Nixon’s spouse. AN? AB?? Are those two different individuals or is that a typo? I'm guessing the latter.

Nixon was interviewed by J.P. Morgan Securities’ Compliance Group and he claimed that the customer's email had been sent in error and was intended for an advisor at another firm who was servicing the same customer. Pointedly, Nixon denied requesting loans or having obtained any funds from firm customers. The AWC then asserts that

When asked his wife’s name, Nixon falsely state that it was “CB” although it was actually “AB” . . .

On a Compliance Questionnaire dated March 12, 2014, Nixon purportedly reiterated his understanding of the firm’s prohibitions pertaining to customer loans and gifts but, nonetheless, failed to disclose same on the form.  

Not Happy With The Answers

According to online FINRA records as of October 24, 2014, J.P. Morgan Securities “Discharged” Nixon on April 3, 2014, based upon allegations that:

REGISTERED REP APPROACHED AND ACCEPTED FUNDS FROM A CUSTOMER FOR PERSONAL USE.

Online FINRA records further disclose that on May 5, 2014, Nixon was “Discharged” by Wunderlich Securities, Inc. based upon allegations that:

MR. NIXON DID NOT PROVIDE FULL DISCLOSURE OF INFORMATION THAT HE WAS AWARE OF THAT WAS TO BE FILED ON HIS U-5 FROM J.P. MORGAN SECURITIES.

Payback, So To Speak

The AWC alleges that Nixon should have disclosed his receipt of the January 2012 $5,000 cash gift from his elderly customer and the October 2012 $2,000 cash gift from a second customer. Similarly, in October 2013, Nixon failed to disclose on the Annual Certification Form his receipt of a $5,000 loan from his elderly customer. FINRA deemed Nixon’s conduct to constitute violations of FINRA Rules 3240(a) and 2010. 

In accordance with the terms of the AWC, FINRA imposed upon Nixon a $20,000 fine; an order to pay $4,550 plus interest in restitution to the elderly client; and a 12-month suspension from associating with any member in any capacity.

Bill Singer's Comment

Compliments to both J.P. Morgan Securities and FINRA for this one. Both in-house compliance and the self-regulatory organization seem to have jumped on this one quickly. That earns an additional kudo.

If Nixon had merely borrowed a few bucks from a long-term client or, in fact, there were modest gifts of cash from some customers, that's one thing. In such cases, the stockbroker often fails to realize the need to refrain from taking the funds and/or to disclose the conduct -- none of which excuses the non-reporting but often offers some mitigation. In this case, however, we have many troubling indicia of evasion. The whole mess with the wife's name. The misleading denials of  the loans/gifts on internal reporting forms. The involvement of an elderly client. The failure to repay the loan. Nixon should be thankful that he was only saddled with a 12-month suspension on top of the fine and repayment.

Now, let’s take an opportunity to review the salient points of FINRA Rule 3240.  See the language of the Rule below with my commentary:

3000. SUPERVISION AND RESPONSIBILITIES RELATING TO ASSOCIATED PERSONS
3200. RESPONSIBILITIES RELATING TO ASSOCIATED PERSONS 
3240. Borrowing From or Lending to Customers 

Bill Singer's Comment: Note that the Rule addresses both borrowing and lending, but that such activities are proscribed here only to the extent that the contra-side of the arrangement is a customer. Member firms can choose to permit registered persons to borrow from or lend to their customers consistent with this rule OR the member may prohibit the practice in whole or in part.  As such, simply because FINRA's Rule sets forth conditions that could permit borrowing/lending does not mean that a given FINRA member is required by the regulator to allow such activity.

(a) Permissible Lending Arrangements; Conditions 
No person associated with a member in any registered capacity may borrow money from or lend money to any customer of such person unless: 

Bill Singer's Comment: Note that the specific proscription here is from borrowing/lending to any customer of "such person" -- the limitation is on contemplated activity with "your" customer and not merely a customer of your firm.  

(1) the member has written procedures allowing the borrowing and lending of money between such registered persons and customers of the member;

Bill Singer's Comment: The threshold requirement is that you cannot borrow/lend with your customers unless your member firm has written procedures allowing borrowing/lending between registered persons and customers of the firm.  If there are no written procedures, you can't get around this by walking into someone's office or making a phone call call to some compliance type and getting a verbal "okay."

(2) the borrowing or lending arrangement meets one of the following conditions: 

Bill Singer's Comment: Preliminarily, FINRA underscores that the Rule does not merely address borrowing from customers but also lending to them.

(A) the customer is a member of such person’s immediate family; 

Bill Singer's Comment: What constitutes an "immediate family" member? Good question, and one that is pointedly answered in section (c), below.  Why is that critical definition not immediately provided here following the first use of the term? Hey, don't get me started with how rules are drafted. Bottom line, one of the five approved categories of your customers with which you can borrow/lend is an immediate family member.

(B) the customer 
(i) is a financial institution regularly engaged in the business of providing credit, financing, or loans, or other entity or person that regularly arranges or extends credit in the ordinary course of business and  (ii) is acting in the course of such business;

Bill Singer's Comment: In addition to financial institutions engaged in the three covered businesses of providing credit, financing, or loans (such transactions typically include, but are not limited to, mortgages, personal loans, home equity lines of credit, and credit card accounts, and also include lending arrangements with an affiliate of the customer), a registered person could conceivably lend to or borrow from a non-financial institution or human being provided that the contra-party regularly arranges/extends credit (but apparently not also financing or loans -- those seem limited to financial institutions) in the ordinary course of business AND is so acting. Clearly, FINRA is warning you that the contemplated borrowing/lending must be in the ordinary course of business.

(C) the customer and the registered person are both registered persons of the same member; 

Bill Singer's Comment: Nothing like owing a co-worker money!  Nonetheless, if the lender/borrower is your customer and also registered at your member, then that satisfies one of the five conditions under this section.

(D) the lending arrangement is based on a personal relationship with the customer, such that the loan would not have been solicited, offered, or given had the customer and the [associated] registered person not maintained a relationship outside of the broker[/]-customer relationship; 

Bill Singer's Comment: If you and your customer have a personal relationship outside of the mere broker-customer relationship (perhaps high-school buddies, weekend softball teammates, or members of the same church) that might qualify as a circumstance in which the loan would be viewed as not springing solely from the broker-client relationship.
or 
(E) the lending arrangement is based on a business relationship outside of the broker-customer relationship;

Bill Singer's Comment: Similar to the "personal" relationship exception, if you have a separate business relationship that of broker-customer (perhaps your customer is a service provider to you in another business or a professional who handles some non-industry business matters for you) that may constitute the fifth condition.
and
(3) the requirements of paragraph (b) of this Rule are satisfied.   

(b) Notification and Approval 

Bill Singer's Comment: It can't be spelled out any plainer: This is about notifying your member AND getting your member's approval.  It's not one or the other.

(1) The registered person shall notify the member of the borrowing or lending arrangements described in paragraphs (a)(2)(C), (D), and (E) above prior to entering into such arrangements

Bill Singer's Comment: First off, the notification requirement must always be satisfied when your customer is not an immediate family member, a financial institution, or an entity/individual in the business of extending credit.  The other side of that equation, is that you must always first notify your firm of the arrangement, if your customer is another registered person at your firm, or if you are claiming a personal/business relationship exists.  Separately, the contemplated notice is prior to entering into the arrangement.

and the member shall pre-approve in writing such arrangements 

Bill Singer's Comment: The Rule requires the member firm to pre-approve in writing the requested arrangement.  You should not rely upon an oral okay -- and I don't care who at your firm tells you that it's okay to go ahead on the oral say-so. Just watch how that person double-tracks if FINRA asks for a confirmation of that advice.

The registered person shall also notify the member and the member shall pre-approve in writing any modifications to such arrangements, including any extension of the duration of such arrangements.

Bill Singer's Comment: Also, you can't play the old switcheroo.  If you asked for permission to engage in X and you subsequently modify the loan (particularly an extension of the loan's term or repayment), then you have to go through the entire notification and pre-approval in writing protocol.

(2) With respect to the borrowing or lending arrangements described in paragraph (a)(2)(A) above, a member’s written procedures may indicate that registered persons are not required to notify the member or receive member approval either prior to or subsequent to entering into such borrowing or lending arrangements. 

Bill Singer's Comment: If you look back up to the top of the Rule, you will see the provision that would permit lending to or borrowing from customers who are also immediate family members (which still isn't formally defined, as yet, at this point of the Rule). Nonetheless, you may not need to notify your firm or get its prior approval if your customer is an immediate family member provided that your member has a specific written procedure waiving said notice and/or approval.

(3) With respect to the borrowing or lending arrangements described in paragraph (a)(2)(B) above, a member’s written procedures may indicate that registered persons are not required to notify the member or receive member approval either prior to or subsequent to entering into such borrowing or lending arrangements, provided that, the loan has been made on commercial terms that the customer generally makes available to members of the general public similarly situated as to need, purpose and creditworthiness. For purposes of this subparagraph, the member may rely on the registered person’s representation that the terms of the loan meet the above-described standards.  

Bill Singer's Comment: As to arrangements involving financial institutions (or credit providing companies/individuals), there is an exemption from the need to give notice or obtain approval provided that the loan will be made on commercial terms generally available to the similarly situated general public (taking into account need, purpose, and creditworthiness). FINRA does not necessarily require you to document those preconditions to your member and your representation may be deemed satisfactory.  The issue here is that you better not be getting a so-called "sweetheart deal."  Bottom line, the arrangement better pass the sniff test.

(c) Definition of Immediate Family 
The term “immediate family” means parents, grandparents, mother-in-law or father-in-law, husband or wife, brother or sister, brother-in-law or sister-in-law, son-in law or daughter-in-law, children, grandchildren, cousin, aunt or uncle, or niece or nephew, and any other person whom the registered person supports, directly or indirectly, to a material extent.   

Bill Singer's Comment: Finally -- here it is, the critical definition. Make sure to check the list and note that it can also cover folks whom you provide material support to on a direct or indirect basis.

********************
Supplementary Material:
.01 Record Retention. For purposes of paragraph (b)(1) of this Rule, members shall preserve the written pre-approval for at least three years after the date that the borrowing or lending arrangement has terminated or for at least three years after the registered person’s association with the member has terminated. 

Bill Singer's Comment: This language requires your member to preserve the written approvals for at least three years from the date the arrangement terminated or at least three years after the registered person's association has terminated with the member. Be careful not to misinterpret this retention provision: You must retain the pre-approval for three years from the date of the loan's termination or the registered person's termination from the subject member.


 

Written: October 28, 2014

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Washington Investment Advisors, Inc.1; IFS Financial Services, Inc.; Peppertree Partners ... Financial Representative Title: Insurance Representative – Financial ServicesSales... more

Oct 27Chase Wealth Management - International Financial Services - Financial Consultant (LICENSES & SECOND LANGUAGE FLUENCY REQUIRED Spanish, Portuguese and/or Mandarin/Cantonese)JPMorgan Chase &New York City, NY

Chase is the U.S. consumer and commercial banking business of JPMorgan Chase & Co. (NYSE: ... Within ChaseChase Wealth Management encompasses our Chase Private Client (CPC), Chase In... more

Oct 25JPMorgan Securities | Administrative Assistant |JPMorgan Chase &New York City, NY

skills JPMorgan Chase offers an exceptional benefits program and a highly competitive ...JPMorgan Chase is an Equal Opportunity and Affirmative Action Employer, M/F/D/V. more

Oct 25Chase Wealth Management - Financial Advisor Associate TraineeJPMorgan ChaseSan Francisco, CA

Within ChaseChase Wealth Management encompasses our Chase Private Client (CPC) andChase ... to a broad range of Chase customers through Chase Investment Advisors. As aChase... more

Oct 21JPMorgan Securities | Client Associate |JPMorgan ChaseSan Francisco, CA

PowerPoint and Excel JPMorgan Chase is an Equal Opportunity and Affirmative Action ... *ASSET MANAGEMENT* **Title:** *JPMorgan Securities | Client Associate | San Francisco*... more

Oct 16JPMorgan Chase Institute Deputy - Project Manager- Executive DirectorJPMorgan ChaseWashington, DC

The new JPMorgan Chase Institute will be a thought-leading initiative backed by the ... results on major projects/programs JPMorgan Chase is an equal opportunity and... more

Oct 14JPMorgan Securities | Administrative Assistant |JPMorgan ChaseNew York City, NY

skills JPMorgan Chase offers an exceptional benefits program and a highly ... compensation package. JPMorgan Chase is an Equal Opportunity and Affirmative Action... more

Oct 14JPMorgan Securities | Marketing Assistant |JPMorgan ChaseAtlanta, GA

role. * Bachelor's degree required. JPMorgan Chase offers an exceptional benefits program ... competitive compensation package. JPMorgan Chase is an Equal Opportunity and Affirmative... more

Oct 13Chase Private Client Investment Associate - Brooklyn, NY (Midwood)JPMorgan Chase &Brooklyn, NY

Chase is the U.S. consumer and commercial banking business of JPMorgan Chase & Co. (NYSE: ... Within ChaseChase Wealth Management encompasses our Chase Private Client (CPC) and Chase... more

Oct 13JPMorgan Securities | Client Associate, 7 & 63 or 66 |JPMorgan Chase &New York City, NY

PowerPoint and Excel JPMorgan Chase offers an exceptional benefits program and a highly ... compensation package. JPMorgan Chase is an Equal Opportunity and Affirmative... more

Oct 11Global Sales Director, Pan-HP - JPMorgan ChaseHPPalo Alto, CA

versees engagements with multiple portfolio solutions. **Job** *Sales* **Title:** *Global Sales Director, Pan-HP - JPMorgan Chase* **Location:** *United States* **Requisition...more

Oct 27Corp Compliance Spec III, US Compliance Regulatory OfficeTD BankMount Laurel, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Wire Transfer Operators II [2]-- SC--Phone Customer ServiceTD BankLexington, SC

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Reporting Analyst II -Fraud Mgmt GovTD BankMount Laurel, NJ

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Mortgage Loan Processor - Mortgage SettlementTD BankLewiston, ME

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Corp Compliance Spec III, Testing (Dep/Money-In/Direct Channels)TD BankGreenville, SC

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Fulfillment Specialist, Deposit Ops-FT: 1:00pm-9:30pm Tues-SatTD BankMount Laurel, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Corporate Compliance Manager - TDAFTD BankFarmington, MI

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 27Teller I - 20hrsTD BankNew Britain, CT

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 25Credit Analyst II/Healthcare/Mercerville, NJ (Quakerbridge)TD BankTrenton, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 24Teller I - FTTD BankFairfield, CT

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 24Teller I - 30hrsTD BankBranford, CT

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 24Fulfillment Specialist, Deposit Ops-FT: 1:00pm-9:30pm Tues-STD BankMount Laurel, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 24Teller I -40hrsTD BankWayland, MA

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 08Desktop Support Representative (103946)TD AmeritradeFort Worth, TX

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 06Senior Java Developer (103938)TD AmeritradeColumbia, MD

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 03Analyst Sr Lean COE (103922)TD AmeritradeSan Diego, CA

* PMP certification (preferred) TD Ameritrade participates in the E-Verify ... TDAmeritrade is a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 03Branch Manager Oakbrook IL (103920)TD AmeritradeChicago, IL

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Senior Manager Database Administration (103863)TD AmeritradeOmaha, NE

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Senior Engineering Consultant (103862)TD AmeritradeColumbia, MD

infrastructure requirements and standards TD Ameritrade participates in the E-Verify ... TDAmeritrade is a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Bank Consultant Flushing NY (103904)TD AmeritradeQueens, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Bank Consultant New York NY (103907)TD AmeritradeNew York City, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Investment Consultant 6th Avenue NY NY (103902)TD AmeritradeNew York City, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 25Examination Manager - Member Regulation, Sales Practice - ChicagoFinancial Industry Regulatory Authority (finra)Riverdale, IL

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Examination Manager opening in our Chicago, IL, location. To be considered for... more

Oct 25Training Manager, Regulatory Training - Rockville, MD or New York, NYFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Training Manager, Regulatory... more

Oct 25Compliance Analyst, Office of General CounselFinancial Industry Regulatory Authority (finra)Washington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Compliance Analyst opening with our...more

Oct 24Curriculum Program Manager, Risk & Surveillance - Rockville, MD orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Curriculum Program Manager, Risk &...more

Oct 24Curriculum Program Manager, Catalog - Rockville, MD orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Curriculum Program Manager, Catalog...more

Oct 24Gateway AgentFinraRockville, MD

We Work to Protect Investors. Join our Team. FINRA is seeking well qualified individuals for our Gateway Agent opening in Rockville, MD . To be considered for this position,... more

Oct 24Curriculum Program Manager, Risk & Surveillance - Rockville, MD or New York, NYFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Curriculum Program Manager, Risk &...more

Oct 24Lead Systems Analyst - Technology, RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Lead Systems Analyst opening in Rockville, MD. To be considered for this... more

Oct 24Lead Systems Analyst - TechnologyFinraRockville, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Lead Systems Analyst opening in Rockville, MD. To be considered for this... more

Oct 23Director-Shared Services Engineering & Operations,TechnologyFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director, Shared Services... more

Oct 22Director-Technology DevelopmentFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director Technology Development...more

Oct 20Director-Shared Services Engineering & Operations,Technology, RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director, Shared Services... more

Oct 20Director-Technology Development, RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director Technology Development...more

Oct 18Regulatory Analyst - OFDMI/ Office of WhistleblowerFinraRockville, MD

We Work to Protect Investors. Join our Team . The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Regulatory Analyst opening in... more

Oct 17Regulatory Analyst - OFDMI/ Office of Whistleblower - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Regulatory Analyst opening in... more

Oct 17Associate Developer in Test - TechnologyFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Associate Developer in Test opening...more

Oct 17Research Analyst III, Regulatory ProgramsFinancial Industry Regulatory Authority (finra)Washington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Research Analyst opening in... more

Oct 15Regional Counsel, EnforcementFinraNew York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Regional Counsel opening in New... more

Oct 15Undergraduate Intern - Technology- Rockville, MD and New York, NYFinraRockville, MD

2015 Summer Internship Program FINRA is dedicated to providing you with an internship opportunity to gain knowledge and experience in the securities industry with an employer that... more

Oct 11Examination Manager - Membership Application Program, Member RegulationFinraNew York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Examination Manager, Membership Application Program opening in New York, NY . To...more

Oct 08Regulatory Analyst - Market Regulation, Trading AnalysisFinraRockville, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Regulatory Analyst opening in Rockville, Md. To be considered for this position,... more

Oct 08Regulatory Analyst - OFDMI-FraudFinraRockville, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Regulatory Analyst - Fraud opening in Rockville, MD . To be considered for this... more

Oct 02Regulatory Coordinator - Member Regulation, Sales Practice - New York, NY(Job Number: 003573)FinraNew York City, NY

Description Relocation assistance is available for exempt internal employees (lump sum allowance only). Exceptions to receiving a lump sum allowance require approval; contact your... more

Oct 02Compliance Examiner - Market Regulation, Trading & Financial Compliance Examinations (TFCE) Options- New York, NY(Job Number: 003500)FinraNew York City, NY

Description Title: Compliance Examiner Department: Market Regulation, Trade Exams & Special Reviews Options Location: New York, NY Grade: 43-46 We Work to Protect Investors. Join... more

Oct 02Compliance Examiner, Member Regulation Sales Practice - San Francisco, CA(Job Number: 003691)FinraSan Francisco, CA

Description Title: Examiner (Future Openings) Department: Member Regulation - Sales Practice Location: San Francisco District Office Grade: 43 to 47 Note: This is a Pipeline...more

Oct 26Attorney, Oversight Liaison & CounselFinancial Industry Regulatory Authority (finra)Washington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Attorney opening in Washington, DC.more

Oct 26Senior Risk Specialist, Operational Risk - Washington, DC or New York, NYFinraWashington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Senior Risk Specialist, Operational...more

Oct 26Attorney, Oversight Liaison & CounselFinraWashington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Attorney opening in Washington, DC...more

Oct 26FINRA Legal Extern, Enforcement (UNPAID)FinraNew York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking well-qualified individuals for our Legal Extern - Department of Enforcement opening in New York, NY . To be... more

Oct 26Risk Specialist, Operational Risk - Washington, DC or New York, NYFinraWashington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Risk Specialist, Operational Risk... more

Oct 26Director - Technology - Rockville, MD - Contractor ConversionFinraRockville, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Director opening in Rockville, MD . To be considered for this position, please... more

Oct 26Compliance Analyst, Office of General CounselFinraWashington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Compliance Analyst opening with our...more

Oct 25Senior Risk Specialist, Operational Risk - Washington, DC orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Senior Risk Specialist, Operational...more

Oct 25Curriculum Program Manager, Catalog - Rockville, MD or New York, NYFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Curriculum Program Manager, Catalog...more

Oct 25Risk Specialist, Operational Risk - Washington, DC orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Risk Specialist, Operational Risk... more

Oct 25Associate Director, Operational Risk - Washington, DC orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Associate Director, Operational... more

Oct 25Training Manager, eLearning - Rockville, MD or New York, NYFinraRockville, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Training Manager, eLearning opening...more

Oct 25Associate Director, Operational Risk - Washington, DC or New York, NYFinraWashington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Associate Director, Operational... more

Oct 25Service Center StockbrokerScottradeWestminster, CO

Service Center Stockbroker - Westminster, CO Job ID: 20141507-9337 Description: Scottrade is seeking an energetic, career-minded professional to join our award-winning financial... more

Oct 25Director - Technology - Rockville, MD - Contractor ConversionFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Director opening in Rockville, MD. To be considered for this position, please... more

Oct 24Training Manager, Regulatory Training - Rockville, MD orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Training Manager, Regulatory... more

Oct 24Gateway Agent - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. FINRA is seeking well qualified individuals for our Gateway Agent opening in Rockville, MD. To be considered for this position, please...more

Oct 24Training Manager, eLearning - Rockville, MD orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Training Manager, eLearning opening...more

Oct 20Corporate Controller FINRAAppian StaffingTampa, FL

Company Description: Appian Staffing is a National recruiting firm that specializes in exceeding expectations by placing the top tier of candidates, and we offer among the top...more

Oct 18Stockbrokers/Broker TraineesNew York Brokerage FirmWestbury, NY

Job Description: We are currently searching for hardworking and self motivated individuals to join our newly expanded office. The role of trainee will allow the individual to work... more

Oct 08Finra Representative IIIManulife FinancialPortsmouth, NH

Signator Investors Inc., John Hancock’s broker dealer, is a client focused organization that is looking for people that have a passion for service and an ability to deliver... more

Oct 08Stockbroker, Series 7, National Firm - High Payout Will Train!Joseph Stone CapitalMineola, NY

Job Description: Stock Brokers Wanted (Will Train) Come work at the headquarters of an established national broker-dealer that caters to producing brokers. We are looking for...more

Oct 04Stockbroker/Financial AdvisorForte Capital GroupNew York City, NY

Company Description: Forte Capital is a full service, independent, brokerage firm located in the heart of the Financial District. We are small enough to give clients the... more

Oct 02Senior StockbrokerArjentNew York City, NY

Company Description: Arjent a leading boutique Investment firm based In Manhattan, New York offering a full service brokerage to Institutions and HNW Private Clients has an... more



 

 
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