An irreverent Wall Street Blog
by Bill Singer

FINRA Expungement Puts Stockbroker In Marx Brothers Comedy

May 22, 2014

I often warn potential clients that it is often just as expensive to defend an innocent person as a guilty one.  Frankly, sometimes it's more expensive to represent someone who is not guilty of the charges.  As a recent FINRA expungement arbitration demonstrates, the cost of representing an individual who was not even named in a lawsuit may be astronomical. All of which reminds me of that famous Marx Brothers routine about the exorbitant cost for asking musicians to not practice -- you couldn't afford it!

Case In Point

In a Financial Industry Regulatory Authority ("FINRA") Arbitration Statement of Claim filed in August 2013, Claimants asserted causes of action including breaches of contract and fiduciary duty, unsuitability, fraud, and negligence in connection with an assertion that Respondent Wells Fargo Advisors, LLC had endorsed an unsuitable investment strategy of maintaining a concentrated United Parcel Service, Inc. (UPS) stock position. Claimants sought $1,500,000 in compensatory damages, punitive damages, under performance damages, interest, attorneys' fees, and costs. In the Matter of the FINRA Arbitration Between Gregory Niemann Living Trust, Leila Niemann Living Trust, and The Niemann Family Revocable Trust, Claimants, vs. Wells Fargo Advisors, LLC, Respondent (FINRA 13-02477, May 14, 2014).

Withdrawn

In December 2013, Claimants' counsel advised FINRA that Claimants withdrew their claims without prejudice against Respondent.

Unnamed But Not Unharmed

In January 2014, Wells Fargo filed a Motion for Expungement to remove the Niemann customer arbitration from non-party Steve John Christensen's Central Registration Depository records ("CRD"). 

Who the hell is Christensen?, you ask -- noting that his name appears nowhere in the pubic customer arbitration caption. Apparently, he was the unfortunate broker of record for the customers.  

Expungement

Without the Niemann Claimants' attendance at the expungement hearing, with the advice that those Claimants took no position on the expungement application, the FINRA Arbitration Panel proceeded to consider the motion on Christensen's behalf. After taking into account the circumstances under which the account was serviced and testimony presented at the April 2014 hearing, the FINRA Arbitration Panel recommended expungement. In offering its rationale, the Panel explained that it had relied, in part:

[O]n non-party Steve John Christensen's testimony given during the hearing on this matter to the effect that he did do what Claimants alleged he did not do, namely: 1) he did advise the Claimants about the risks associated with maintaining a concentrated position; 2) he did recommend an alternative plan that involved elimination of this concentrated position; and 3) he did advise the Claimants about an option available for mitigating certain risks associated with the Claimants' concentrated position, which the Claimants chose not to do. In reaching this finding, the Panel has further relied on the fact that Claimants dismissed their claims without Respondent filing a response and without the payment of any money or compensation.  

Bill Singer's Comment

According to online FINRA records as of May 22, 2014, Wells Fargo denied the customer's complaint seeking $188,000 in damages, which it had received on December 13, 2005. The online "Allegations" and "Broker Statement" dated January 11, 2006, assert, respectively, that:

POWER OF ATTORNEY OF TEXAS RESIDENTS ALLEGES IN WRITING TO THE SEC THAT HER PARENTS FORMER FINANCIAL ADVISOR ALLOCATED THE SUBACCOUNTS IN THE CLIENT'S [sic] THREE VARIABLE ANNUITY CONTRACTS IN FUNDS THAT WERE AGGRESSIVE GROWTH AND CAUSED LOSSES, WHEN IN FACT THE LOSSES IN HER PARENTS' ACCOUNT WERE CAUSED BY WITHDRAWALS REQUESTED BY CLIENTS, AND ALL PROPER FORMS WERE SIGNED. POA FURTHER STATES THAT FA SURRENDERED ANNUITIES PREMATURELY TO GENERATE SURRENDER CHARGES, WHEN IN FACT ONLY ONE ANNUITY WAS SURRENDERED PURSUANT TO A 1035 EXCHANGE IN OCTOBER OF 2000. THE EXCHANGE GENERATED A SURRENDER CHARGE AND WAS CONDUCTED DUE TO THE POOR PERFORMANCE OF THE EXISTING ANNUITY. ALL MATERIAL FACTS WERE DISCLOSED TO THE CLIENTS. THERE IS NO EVIDENCE OF WRONGDOING.

THE LOSSES IN THE ACCOUNT WERE CAUSED BY WITHDRAWALS REQUESTED BY CLIENTS. THE SUB ACCOUNT ALLOCATION WAS NOT CONTRARY TO CLIENTS' RISK OBJECTIVES. FA CONDUCTED SUITABILITY ASSESSMENT ON 1035 EXCHANGE. POA HAS BEEN RECEIVING STATEMENTS SINCE 2002, DELAY OF OVER TWO YEARS UNREASONABLE SINCE ANNUITIES PURCHAGED [sic] IN LATE 1990S. CLAIM DENIED. FAA COMMENTS: "THE ALLEGED TRANSACTIONS WERE SUITABLE AND AUTHORIZED, AS WELL AS FULLY DOCUMENTED, BY ALL NECESSARY PARTIES. THE POA'S HAS [sic] FAILED TO ACCOUNT FOR WITHDRAWALS AND THE TIMING OF THOSE WITHDRAWALS. A RECENT CLIENT SURVEY CLEARLY INDICATES THAT CUSTOMER'S [sic] WERE MORE THAN SATISFIED WITH OUR SERVICES BY GIVING US THE HIGHEST POSSIBLE RATING OF "HIGHLY SATISFIED" FOR BOTH "HOW WELL DO I UNDERSTAND YOUR FINANCIAL GOALS" AND "HOW WELL DO I COMMUNICATE WITH YOU."

According to online FINRA documents as of May 22, 2014, after having their 2005 customer complaint denied in 2006, the Niemann accounts filed a FINRA Arbitration Statement of Claim, which apparently was received by Respondent Wells Fargo on August 30, 2013. At this time, the alleged damages mushroomed to $1,500,000. Thereafter, on December 12, 2013, the following "Allegations" and "Broker Statement" assert, respectively:

CLAIMANTS ALLEGE THAT IN OR AROUND 2001 UNSUITABLE RECOMMENDATIONS WERE MADE TO MARGIN A CONCENTRATED POSITION IN UPS STOCK, WITHOUT ADVISING OF RISKS OR RISK ;MANAGEMENT STRATEGIES

THE CLAIMANTS' CLAIM AGAINST WELLS FARGO FOR "FAILURE TO COLLAR OR PROTECT (THEIR) UPS STOCK" IS FACTUALLY INCORRECT, WHICH MAKES THEIR ACCUSATION COMPLETELY UNFOUNDED. IN THE ARBITRATION CLAIM, THE CLAIMANTS ALLEGE "WELLS FARGO FAILED TO RECOMMEND A COLLAR AND/OR PROTECTIVE PUT OPTION AS A RISK MANAGEMENT STRATEGY TO PROTECT [CLAIMANTS'] CONCENTRATED POSITION IN UPS STOCK". NOT ONLY DID WELLS FARGO RECOMMEND SUCH A STRATEGY, THE CLAIMS ALSO IMPLEMENTED THIS RISK MANAGEMENT STRATEGY. THE FACTS ARE UNDENIABLY CLEAR; WELLS FARGO HAS SIGNED CONFIRMATIONS TO PROVE THAT IT RECOMMENDED AND IMPLEMENTED THE EXACT STRATEGY THE CLAIMANTS' CLAIM SHOULD HAVE BEEN IMPLEMENTED. WELLS FARGO INTENDS TO VIGOROUSLY CONTEST THESE INACCURATE AND UNFOUNDED ALLEGATIONS." **CLAIMANT WITHDREW HIS CLAIM AGAINST RESPONDENT WITHOUT PREJUDICE ON DECEMBER 12, 2013.

Permit me a brief, albeit impassioned, rant, yet again, about the inequities of FINRA's expungement protocol for cases in which an: 
  • unnamed registered person is involved in a settled or withdrawn public customer arbitration and 
  • the customer did not oppose the requested motion for expungement and 
  • the arbitration settled for "nuisance value" or for no cash payment whatsoever and 
  • the unnamed party did not contribute to any settlement and 
  • a FINRA Arbitration Panel has determined that the unnamed party did not engage in any misconduct relevant and material to the allegations.
Why do I rage about all those "and" factors? For starters, they do not present a particularly rare or nonrecurring fact pattern.  Moreover, please consider this admonition in the expungement decision in Christensen's favor:

The Panel recommends the expungement of all references to the above-captioned arbitration from non-party Steve John Christensen's (CRD # 1787459) registration records maintained by CRD, with the understanding that pursuant to Notice to Members 04-16, non-party Steve John Christensen must obtain confirmation from a court of competent jurisdiction before CRD will execute the expungement directive. 

Unless specifically waived in writing by FINRA, parties seeking judicial confirmation of an arbitration award containing expungement relief must name FINRA as an additional party and serve FINRA with all appropriate documents.

What do those two seemingly innocuous paragraphs in the expungement decision mean? Christensen is a registered person who was not named as a respondent in a public customer arbitration, which was subsequently withdrawn without settlement after having been denied years earlier as a customer complaint years. Additionally, in response to his motion for expungement of that customer matter, the Panel found that Christensen did not engage in wrongful conduct. Despite all of that, the Panel is relegated to issuing nothing more potent than a "recommendation" of expungement. 

What is Christensen supposed to do now?  

Oh, he's supposed to continue to pay a lawyer (assuming that a former or current employer isn't prepared to foot the bill) to take this FINRA Arbitration Panel "recommendation" to a state or federal court and obtain a court Order. Then, assuming that a court entertains the application within his lifetime, Christensen is then supposed to present the Order to CRD and, thereafter, hope that within his lifetime the ponderous bureaucracy expunges the offensive commentary from his record. Mixed into that stew is an obligation to petition FINRA to waive the requirement to name the self-regulatory organization as a party to all this legal fiction and nonsense. 

Whether Christensen's legal tab for the expungement will be fully paid for by Wells Fargo is not the point. Many individuals who find themselves in the same predicament have moved on from the employing brokerage firm where the customer complaint occurred and such former employers may not be disposed to foot the bill (and some former firms may no longer be in business).  

Without any doubt, there is tremendous validity and merit in NOT permitting named or unnamed registered persons to simply obtain a self-executing expungement from a FINRA Arbitration Panel. For far too long, the FINRA community has abused such relief in a way that has burdened Wall Street with recidivists and fraudsters. I get that. I support appropriate restrictions to deter such circumstances. Notwithstanding, in cases where all the "ands" noted above exist, it is a travesty to burden largely innocent men and women with the investment of time and money required to exonerate their besmirched names under circumstances that demand a fairer, cheaper, and more expeditious process. 


Also READ:

Permalink

Search BrokeAndBroker

Related Topics

Previous Entries

Tag Cloud

Bill Singer BrokeAndBroker FINRA Arbitration AWC SEC Expungement BrokeAndBroker.com BrokerAndBroker Guest Blog Employment Guest Blogger Wells Fargo Street Sweeper Aegis Frumento Bill SInger Jobs OBA U5 Fraud Promissory Note U4 Email Merrill Lynch Morgan Stanley UBS Defamation EFL CRD BrokeAndBroker Elderly Wire Fraud InSecurities Statutory Disqualification OHO Whistleblower NAC Suitability PST FBI Forbes DOJ Supervision Citigroup Ponzi ALJ Rule 3270 BrokerCheck Borrowing Form U4 IRS SDNY Expenses OIP Pro Se Willful Supreme Court Rule 8210 Securities Industry Commentator Outside Business Activity Felony Bank Ameriprise Rule 2010 Dodd Frank WSP Rule 2080 Wrongful Termination Discretion Form U5 Discovery IRA Wachovia RIA Raymond James Business Expenses JP Morgan Insider Trading Mail Fraud Punitive Damages Bar NASD Conversion Wife Bankruptcy TRO Edward Jones Rule 1122 CCO Husband Margin Stephen Kohn Forgery Checks Estate Willfulness arbitration Settlement Rule 3240 Tax LPL Schwab 2Cir Trump Commissions Wall Street Employment Tuesday NYSE Credit Card Outside Business Activities Promissory Notes CFTC Madoff Small Firm Beneficiary Corrective Action Statement FAA Options Insurance Rule 3040 Frumento Annuities Private Securities Transaction Injunction Bank of America Impersonation Tax Liens Rule 3280 Antitrust Facebook Goldman Sachs Power of Attorney Real Estate Due Diligence Crypto Indictment Rule 12206 Customer ETF Exam Trust TD Ameritrade Stay Remand Tax Lien OWB Street Legal Mortgage ATM Misdemeanor Test SRO Retaliation Offer of Settlement Spouse Signature OTR Discrimination Trustee Solicitation Eligibility Rule Away Account COVID Securities Fraud Complaint Explained Decision Annuity Barclays Motion to Dismiss Case In Point Jurisdiction ACQ VA Loan Rule 2510 Sanctions NASDAQ Schapiro Wire email POA Initial Decision Spouses Lien DCCir Appeal Blockchain Rule 4511 ARS Unauthorized Discretion Reg SP Failure to Supervise CRS JPMorgan T&P Motion to Vacate Unsuitability Burris Liens Money Laundering Class Action NSF Employee Forgivable Loan Rule 4530 Fidelity HFT Rule 12200 Conspiracy E*Trade Mandatory Arbitration 9Cir PCAOB Bonus Great Recession Unfair Competition Flash Crash Retirement Cease And Desist Compliance Deutsche Bank Reimbursement AML Personal Expenses NASAA RBC Signatures Dissent REIT FINRA Board Continuing Education LOA Willfully Rule 3010 Fiduciary expungement Divorce Sexism Manifest Disregard Disgorgement Severance MSSB 10Cir Chase Vacatur Scottrade Hacking Rule 3110 Huffington Post Customer Complaint Sexist Credit Cards Broker Protocol Due Process Undisclosed Settlement Variable Annuity Deceased Internet Spoofing Disclosure Hacker Bharara Gallagher Unauthorized Trading Will Identity Theft IAR Indemnification Rule 3050 RRBDLAW.com brokeandbroker Cryptocurrency Lehman Brothers Bitcoin BD SDFL Social Media Fees Malware MC-400 Registered Rep Magazine Board Stockbrokers Rule 12904 Self Regulation Examination Variable Annuities Away Accounts Zipper Rule 9552 LIBOR Solicited Lucia Wey Forex Private Placement employment Annual Compliance Questionnaire Audit Wedbush Elder Abuse Loans Statute of Limitations Coronavirus 4Cir Website Trading Platform Apple Gensler Commission FINRA Arbitration Widow Stifel Letter of Authorization Kokesh Emails RMBS jobs Unsolicited Postponement 3Cir Charles Schwab Brummer Second Circuit 2nd Circuit Net Capital Rule 2111 Exhaustion of Administrative Remedies Crowdfunding Public Interest Arbitraiton Dakota Securities Hedge Fund Breach of Contract OIG PIABA Whistleblowing Prison BrokeAndBroker Bill Singer Confidential Information Credit Suisse WSPs Waiver Bonds Lehman Registration Private Securities Transactions BOP Rule 12805 FINOP Rule 2150 PNC Bureau of Prisons Morgan Keegan CMA Motion to Confirm Margin Call Hilton Weiner Newman Unjust Enrichment bill singer insecurities China NYAG Unsuitable Bear Stearns guest blog BrokeandBroker Board of Governors Racism Rule 13200 JPM aegis frumento Mother 9/11 Robinhood Imposter Cheating RR Time And Price Suspension Non-Solicitation IPO ADA CE Judgments Plea Debit Card MetLife Series 7 Telephone Diversity IC3 RRBDlaw.com guest blogger BrokeAndBroker.com Blog FOREX SunTrust Sanction Guidelines TOD Marijuana Sexual Harassment Mutual Funds Compensation Non Solicitation CPA Restitution Rule 2081 Absolute Immunity TCR Elder Fraud Restaurant Embezzlement Regulation SP Auction Rate Securities WB-APP Concentration Finra Charge Stifel Nicolaus Rule 2210 Piwowar Tortious Interference Rakoff Knight EDNY Raiding Enforcement 11Cir NDCA Puts Joshua Brown Broke And Broker Check Kiting Obstruction of Justice NoCA Employment Agreement Churning DOL Leggett Oppenheimer Protocol Counterclaim FNMA 1Cir JOBS Act Confirm Private Placements Covid Membership Continuance Puerto Rico Botkin Reg S-P CNBC Statutory Disqualification Committee OSHA Lawyer Gold Small Firm Governor Whistleblowers Rule 4513 Rationale Testimony supervision Funds Pennystocks Irreparable Harm Bloomberg Executor Trade Secrets Bandimere Michael King Associates Termination money laundering Written Supervisory Procedures Confidentiality Robert Cook Hurry VIX Rule 13805 Shah Gilani Inability to Pay Testing PN SAC Deferred Compensation Test Center TSSB Affinity Fraud Customers Feigenbaum Sarbanes Oxley Cannabis Rule 12504 Woody Allen securities industry commentator Information Research Standing Conflict Lawyers Wine Pennystock Dementia Check Form ADV fraud Michael King Banc of America Saad Excessive Trading USERRA 10b-5 CEO Taxes Circuit Court DNJ Wire Transfer Leveraged ETF Ketchum Biden Medicare Stanford Reg D Preliminary Injunction ING Phishing Johnny Burris AAA Article V Passcode High Frequency Trading Corruption Aleynikov Bank Fraud Day Trading Securities America HSBC Sales Assistant MF Global Confidential Customer Information Morgan Stanely Unregistered Appointments Clause Federal Reserve Rosenthal Recruiting Charity EIA Service Immunity TheBlot Khuzami Affiliate Moon CGMI Rule 2430 Side Bar NRF Rule 12212 Rule 21F Teleconference Marketplace Self Regulatory Organization Probate signature White Google CDO Ethereum ICO Joint Account Hester Peirce Over Concentration 10b-10 Cantor Fitzgerald NPR ACH Layering FINRA AWC Unauthorized Practice of Law Beneficiaries IM Attorneys Fees Aguilar Bid Rigging Privilege Argentina Commodities Fraud 6Cir Morgan Stanley Smith Barney Stipulated Award Disability McDuff Amazon Casino David Sobel Wanger Mutual Fund Conflict of Interest Sexual Discrimination Rule 9554 Kon Extraordinary Circumstances Consent Order State Actor FMLA Spoliation Superior Court Chase Investment Services 5Cir 401k BrokeAndBroke Obstruction Lincoln Financial Statement of Corrective Action Chief Compliance Officer Poteroba Medical Condition Laptop Star Wars Motion to Compel Vault RICO Congress Parking Rule 3030 Third Party Vendor DMD Accounting Hearing Rule 3310 Constitution Whitman Death Ride the Thunder Pruco AXA OCIE Eligibility Finder\'s Fee Vietnam FINRA Small Firm Honorarium Smith Barney Relevant Disciplinary History Marine Corps Trader Marines Negligence 6th Circuit Corzine Default Guitron Penson Failure To Supervise Subpoena Talman Harris Outside Account Yesenia Guitron Online Government Accountability Project Self Directed PAQ Nietzsche JPMS Administrative Remedies Hugh Hewitt Sharemaster YouTube Fines 401(k) Counterfeit Texting Commissioner Stein Kiting S&P Blank Forms SD Florida TIC FCPA Escrow mail fraud Respondeat Superior wire fraud Arrest securities fraud WaMu RRBDlaw Fifth Amendment BATS Series 79 Scottsdale Resignation Tax Fraud Rule 1031 Password Capital Gains Hotel Conflicts Rule 2370 Johnson Equity Indexed Annuities Money Market Commodities Fowler Outside Accounts Racial Discrimination UIT Trading Judgment Stop Loss Copyright Hospital Elder Law Do Not Call Daughter Dell Control Person Investor Alert Fine Female Data Backstage Wall Street Reuters Attorneys\' Fees Cold Spring Advisory Group Guest Bloggers Red Flags Jennifer Tarr LLC Regulation S-P Chase Bank Civil Rights Reform Confirmation OWWP Regulation Fee WhatsApp FAP ESOP Inmate Acosta DCO Res Judicata elderly Withdrawals Obama Taft Correctional Institution FCI Beaumont FCI Microcap Elles Peirce Crime Department of Justice Risk Christian Stanley Extraordinary Cooperation EDPA Reverse Life Insurance Non Solicit Permanent Bar Offset Extortion Life Insurance Selling Away EEOC Falsification First Amendment Libel Client Information Fiduciary Duty Revocation Turnover Scholander SP Moore Netschi FOCUS Arbitration BrokeAndbroker VXX BrokerAndBroker.com Slander Rule 13504 Book of Business Mistake Prudential Rule 9216 Rory Flynn Electronic Communications Tesla Ethics Puerto Rico Bonds Disciplinary History Gross CD Son Chevron Chiasson 11th Circuit Thain Blackbook Title VII Penalty GameStop Wires Zoom Annual Audit 17a-5 Harassment David Lerner NYG Capital Stockbroker Financial Professionals Coalition Oral Discretion Verbal Discretion Liquidation Schneiderman Self Reporting Outside Counsel Relevant Gamification 40 Act Motion Timban WBAPP Interactive Brokers Transamerica Meals Settling Away Investment Adviser Newport Coast Securities NY Life SIFMA For Cause Inside Information wrongful termination Expert Witness Pension Subject Matter Jurisdiction MSPB Newbridge In House Counsel Non-Prosecution Agreement Kent Vacate Berthel Fisher Punitive Income AWC. FINRA Guardian Rule 144 Motion to Postpone Oilpro Exemption Mantar Tax Advice Apartment In Connection With Last Known Address Office of Special Counsel bank Willfull Confidential Customer Information ALJ Grimes Exhaustion Doctrine Allocation Cherry Picking GAP Summary Judgment ADR Kovack Securities Stephen A. Kohn defamation Unauthorized Trades Particularity Calls Pacifico Stipulation Deceased Customer Grievance Financial Disclosure Women PSRO Bill singer Eric Stein SDOH Notice Production Bonus Transitional Bonus Purshe Kaplan Vungarala Section 1332 Schottenstein Preet Bharara Rule 13201 Shotgun Pleading Texas State Securities Board SIE Private Actor Prime Bank Subway College EDVA NMS MDLA Ecuador Fidelity Brokerage Services Rule 1210 Checking Ruder Task Force Audit Committee FDA DMCA MAP DWI DRS Fiero JP Morgan Securities AMC Nicolas Corcione Fundacion Nicor SDCA NFT Third Party Beneficiary GME Motion to Compel Arbitration Fernandez Panama Trade Practices Jon Corzine Hackers ALJ Foelak Rule 21F-17 Undertaking whistleblower Bequest Elon Musk SLUSA Liu Capitalism Bezos Branch Manager AI Rule 12511 Clayton Voya Expert Public Arbitrator Lek NPI Exception Reports annuities finra Sears Cryptocurrencies Promoter Lorenzo National Securities QuadrigaCX Ten Commandments Form TCR Non-Solicit NYLIFE TradeStation FINRA Foundation reimbursement expenses Hayden Production God Dostoevsky Burden of Proof Howey sexism Jay Clayton Game of Thrones Section 206 Compliance Questionnaire Law School Mattera Romer Arbitrator FinCEN Laser Patriot Act Hostile Workplace Trainee Fee Bank Secrecy Act Kennedy Arbitrability NML DPA Deferred Prosecution Agreement Silver Diamonds Malice Banks Legend PHC Books And Records Examinations Cybercrime At Will Overtime Wages Beatles Lewis Carroll Springsteen McCartney Cybersecurity South Park Gnomes Payroll Undercover Travel Preliminary Determination Hearsay Rules of Practice Age Discrimination Practice Sale ADEA Excel Work Product Motion To Dismiss Stock Promotion Coin Swaps Khan Binary Options Compromise Short Sale Mary Jo White Compliance Officer Fourth Amendment Allstate Disparate Treatment Molchatsky Initials Customer Files Led Zeppelin Series 66 EB-5 Gabelli Proctor Wire Transfers iPhone Mail Janney Montgomery Scott Martoma CMO Collateral SEC Rules of Practice Dylan Leveraged ETFs Evidence Father Address Supervisor State Farm Bill Singer BrokeAndBroker Merger Dinner Wells Fargo Advisors Gifts BIll Singer Transfer CAT Executrix BBVA Corporate Credit Card Tennis Court Rule 13904 Retired Woman With Cane ESG Reason for Termination Nationwide Powell Fraudulent Inducement Rule 3210 Back Dated Tysk ACT! Reg SHO Exception Report Impersonator Training Altered Frivolous BitTorrent Kierkegaard FINRA Eligibility Rule Vaccarelli Bartko Court of Appeal Salman NRSRO Municipal Advisor Retroactive Retroactive Bar Collateral Bar Motiion to Acquit Alcoholism Rule 13104 Currency Rule 12104 Merill Lynch Investment Advisers Act Rule 13206 Jury Instructions Covid-19 Joint Production Pershing Communications Municipal Bonds ETFs Well Managed Portfolio Exotic ETF Principal Forfeiture Sterne Agee Witness Tampering JPMorgan Chase Rule 420 Quasi Governmental Tippee Tipper Life Settlement Altered Records Reasonable Clearing Firm Solomon Non Compete Obamacare Harris Bob Dylan Turbeville Motion to Exclude Sharing Agreement false statements Discharge Rule 13212 Nasdaq Orders Daspin MBS Books and Records Rule 2330 Lexicon Traders Ronald Filler Success Fee Twitter Constructive Discharge Goble DDC FNI Media JAMS Countrywide Broy Tran Bank Guarantee Flash Drive FTC Disney William Faulkner Bribe Guardianship Galleon 8210 9th Circuit US Airways Justice Brokeandbroker.com Koval RRBDLAW Cellphone Theft Skimming Hurtado IBM Baby Boomers Criminal House Financial Services BrokeandBroker.com Credit Repair NFA Spam Press Release Martin No Show Mary Schapiro DAO Kenneth Starr Murray Varney Personal Information Statute of Limitation Walter Advisor Placement Group Costa Rica Schumer Espionage Dissident Ineligibility Diabetes Dow Naskovets Securities and Exchange Commission Margin Calls Anderson Citibank 1099 SIPC Investacorp Reverse Merger Expense HBO AIG Boyland Lee Sex Merrill 529 Plan Wang Scam Hertz