Blog by Bill Singer WEEK IN REVIEW

July 2, 2016

OPEN CALL For BrokeAndBroker.Com Blog Guest Contributors

If you would like to pitch a Guest Blog for the Blog, please send a brief outline of the proposed article to I don't open attached files from unknown senders, so make sure that your pitch is in the text portion of the email. I welcome all views and perspectives, even when they erroneously conflict mine. Please do not send me puff or marketing pieces. I am accepting serious regulatory/legal/compliance commentary on important cases and developing issues. Also, I am seeking thoughtful observations about investing and market trends. Customer advocates and unrepentant industry apologists are all welcome. There is no compensation offered; however, I am happy to include in any article your direct contact information and professional biography, as noted in this recent offering: "Get On Board With New FINRA Rule 2273 Before You On-Board Registered Reps'" ( Blog, by Myles Blechner, July 1, 2016). If you can demonstrate a responsive audience for your musings, I will even consider a permanent column for you on my site. If you've got the writer's itch, scratch it at the Blog. Send submissions to:

Get On Board With New FINRA Rule 2273 Before You On-Board Registered Reps
 July 1, 2016
by Myles Blechner, Senior Consultant, NCS Regulatory Compliance

Effective November 11, 2016, Financial Industry Regulatory Authority ("FINRA") FINRA Rule 2273: Educational Communication Related to Recruitment Practices and Account Transfers will require member firms who recruit Registered Representatives to deliver an educational communication to all clients being solicited to transfer their accounts. NCS Regulatory Compliance Senior Consultant Myles Blechner walks you through the new requirements and provides you with full-text versions of Rule 2273 and the FINRA Educational CommunicationREAD

A former registered representative seeks about $600,000 in damages from his former employer amid allegations of defamation and wrongful termination. It's a familiar refrain; however, that familiarity makes nothing less painful for any former employee.  The disgruntled rep girded for battle and represented himself. That whole pro se thing is often a prescription for disaster but no so this time around. The Claimant walks away with his pockets filled with cash and an expungement of his record. READ

Welcome to FINRA's masquerade ball where the self-regulatory organization hides two entire countries behind a mask of secrecy in a recent regulatory settlement despite naming one American state and one British territory and one sovereign nation in the same document. All of this inconsistent and ironic subterfuge takes place on the pages of a settlement agreement involving alleged failures to disclose. After you get lost in that lonely game FINRA plays, sit back and enjoy an absolutely amazing music video with George Benson, Chaka Khan, and Ray Charles! READ

If you read through today's FINRA arbitration commentary by Bill Singer, you will come across what seems a fairly mundane employment dispute between former employee Bell and his former employer Wedbush, with Bell seeking at least $1.25 million in damages. As is often the case, the FINRA Arbitration Decision is minimalist in its presentation of the underlying dispute; and about all we know is that the Claimant asserts that he sustained damages as a result of various breaches and a wrongful discharge. At the end of today's blog is a Postscript, which may open your eyes and drop your jaw when you realize that there was far more to this employment dispute than was presented in the Decision. READ

And so it continues. Achilles dies. The Greeks build a wooden horse. Troy falls. Odysseus attempts to make his way home but is shipwrecked. Administrative Law Judge Elliott returns to Washington, DC and demolishes a food-vending machine at the Securities and Exchange Commission. One of the SEC Staff realizes that they have left the retired woman with cane behind but when they ask Federal Bureau of Prisons to release her, they receive a letter providing instructions on how to file a Writ of Habeas Corpus. This all sound far fetched and comical?  Not as much as you might think. Sadly, not by a long-shot. READ