Together the firms will pay out over $9 million relating to the sale of leveraged and inverse exchange-traded funds (ETFs) alleged to have been sold to customers without reasonable supervision or a reasonable basis for recommending the securities. This total payout includes fines of about $7 million and restitution in the amount of $1.8 million, to be paid to specific customers that invested in what were deemed unsuitable leveraged and inverse ETF purchases. Wells Fargo will pay a $2.1 million fine and $641,489 in restitution; Citigroup will pay a $2 million fine and $146,431 in restitution; Morgan Stanley will pay a $1.75 million fine and $604,584 in restitution and UBS will pay a $1.5 million fine and $431,488 in restitution.
Since ETFs are by nature complex products, FINRA has taken the position that firms must ensure that they have trained their sales force and have engaged in reasonable due diligence to confirm that their sales representatives understand ETF's prior to sale to retail customers. Most often ETFs are comprised of either registered unit investment trusts (UITs) or open-end investment companies whose shares are comprised of interests in securities that are tracking a benchmark or index. ETF's can be leveraged or inverse. Leveraged ETFs are intended to deliver multiples of the performance of the index or benchmark tracked. While the inverse type of ETF seeks to profit from short positions in derivatives in a falling market.
FINRA's findings revealed that during the period from January 2008 through June 2009, these firms failed to provide adequate supervisory systems monitoring the sale of both types of ETF's. Further, FINRA found that due diligence was lacking to assess the risks and features of these products which would be necessary to recommend these to retail customers. Suitability was also an issue that arose from these sales, as some customers with conservative investment profiles were recommended to buy these products that inherently carried risk and hold them through a volatile market during the period reviewed.
The Wall Street law firm of Gusrae Kaplan Nusbaum PLLC provides legal counsel and representation to firms and broker-dealers in establishing and maintaining proper supervisory systems and all related compliance with FINRA and SEC rules and regulations. Please contact our law firm to speak with one our lawyers about our advisory services and representation before all regulatory agencies and courts in the field of securities law.
Specific allegations, that were neither admitted nor denied by the firm, included claims related to its published research and failure to supervise or monitor related communications and trading. The problem apparently arose in what were known as "trading huddles" consisting of weekly meetings between research analysts, traders and equity salespeople. In these meetings, specific securities could be discussed and analysts would openly share their thoughts about possible ratings changes and conviction list status of securities. Clients could have access to these huddles, as well as other calls in which the analysts' thoughts were revealed by those in the huddles.
Stating that the firm had an "environment of heightened risk in which material non-public information concerning analysts' published research could be disclosed to its clients," FINRA's Executive Vice President and Chief of Enforcement, Brad Bennett also noted that "... the firm did not have an adequate system in place to monitor client trading in advance of changes in its published research."
What troubled FINRA and the SEC, was the risk of disclosure of material non-public information, including possible status and ratings changes within these huddles. The concern was that the firm did not provide for adequate controls "to monitor communications in trading huddles and by analysts after the huddles."
Related issues were the alleged failure to have a monitoring system that was sufficient to watch for trading in advance of ratings or conviction lists changes, particularly in employee or proprietary trading accounts, with institutional customers and other accounts. The contention is that spikes in trading volume and increased trading in certain types of accounts could have been detected had the monitoring been in place.
New York's Gusrae Kaplan Nusbaum PLLC represents broker-dealers in all aspects of securities and commodities litigation and regulatory and enforcement actions. We regularly advise clients on supervisory and monitoring requirements in order maintain regulatory compliance. Please contact us to speak with one of our lawyers about our experience and practice.
]]>The charges in this matter were brought in May 2010. The panel reviewed a time frame from 2005 through 2007 and found that the firm charged excessive markups in over 1500 transactions during this period. In both municipal bond and CMO trades of investment grade or above, the market price was actually lower than that charged by the firm.
The panel found that this was out of compliance with FINRA rules that require fair and reasonable markups based on various factors and circumstances. These factors include such things as the amount involved in the transaction, the type of security and the market availability of the security.
In this matter, the firm was charging municipal bond markups of 3 percent to nearly 6 percent and CMO markups of about 4 percent to nearly 12.5 percent. These markups were charged no matter what amount was invested. The result, according to the panel, was a lower yield for investors since the market price was consistently lower than that charged by the firm.
After an exam in 2004, the firm received a Letter of Caution regarding markup practices and in 2009 the firm received Wells Notices on these practices. According the panel, the firm did not adjust its practices in light of these warnings. This failure was taken into account in the discipline imposed. The firm was fined $2.3 million for these markups and was also ordered to pay restitution of over $1.4 million, plus interest, to customers. The firm's head trader was fined $200,000 and was suspended for six months from the securities industry.
In addition, the firm was found to have an inadequate supervisory system in place to monitor pricing of municipal bonds and CMOs. Other internal issues were involved concerning the recording of timing for municipal bond orders and related issues.
Wall Street's Gusrae Kaplan Nusbaum PLLC represents firms and broker-dealers in regulatory and enforcement matters. We regularly advise clients on compliance and defend industry members before all regulatory entities in matters involving a broad spectrum of issues for broker-dealers and firms. Contact our law firm to consult with one of our attorneys and to learn more about our law practice.
The investigative matter is in connection with the firm's sale to investors of about $60 billion in residential mortgage-backed securities. According to the filing, the SEC has sought documents that date back to September 2011. Wells Fargo agreed to produce, but allegedly has failed to do so. The filing by the SEC is an Application for an Order Requiring Compliance with Administrative Subpoenas.
SEC staff in the San Francisco Regional Office has been in the process of seeking documents relating to the firm's underwriting guidelines and due diligence materials. The SEC states that Wells Fargo has not yet produced what it agreed to provide.
The background on this action involves the SEC's investigation of offerings made from 2006 through early 2008. The SEC is seeking to determine "whether Wells Fargo made material misrepresentations or omitted material facts." There is no allegation that there was any wrongdoing, but the Commission claims it cannot proceed with the investigation without the relevant documents sought from the firm.
The Commission has reviewed sample loans from the mortgage-backed securities offerings and has concerns that despite some loans having failed to comply with the firm's underwriting standards, they were not pulled from sale to investors. The SEC wants to determine whether investors were told that the loans were in compliance with these standards, when they are not.
The New York firm of Gusrae Kaplan Nusbaum PLLC advises broker-dealers and firms in all aspects of regulatory compliance. Our skilled and experienced lawyers represent industry members before all regulatory entities. Contact our law firm to consult with one of our attorneys.
According to FINRA's allegations, over a three-year period approximately 3,600 customers were charged excessive markup and markdowns in corporate and agency bonds. At rates between 2.73 percent to about 10 percent, FINRA alleged that the transaction costs in relation to market conditions and services rendered were too high. A more reasonable charge is said by FINRA to be between one and five percent. FINRA also claimed that the firm did not use "reasonable diligence" for its customers in its purchase or sale of corporate bonds at prices "as favorable as possible under prevailing market conditions."
Supervisory system deficiencies were also raised by FINRA in the area of fixed income transactions. Citing problems with the firm's review of markups and markdowns under 5 percent and the use of par value pricing rather than actual value pricing, the firm will now alter its written supervisory procedures surrounding review of markups and markdowns, including "best execution" with regard to fixed income transactions.
Overall, FINRA noted that it will continue to focus on fair pricing standards and reaffirmed its position that firms must operate within "appropriate standards for fair pricing in debt transactions." The firm settled this matter without admitting or denying the charges made by FINRA.
The lawyers of Wall Street's Gusrae Kaplan Nusbaum PLLC represent firms and broker-dealers in all areas of compliance, as well as before regulatory agencies. Contact our law firm to talk with us about your representation or advisory needs. We are a firm of experienced securities and compliance litigators, providing a wide range of advisory and litigation services to our clients.
]]>The SEC's complaint alleges that the former executive used confidential information about his company's upcoming bottling plant acquisitions to secure illicit profits. The SEC alleges the former executive used his spouse's brokerage account to buy company stock after he learned that a significant acquisition was about to take place.
The defendant is also alleged to have had access to, and possession of, highly confidential information about CCE's business plans. He is alleged to have signed many non-disclosure agreements about potential acquisitions, as well as having received black out notices on other deals the company was about to make.
In this particular transaction, his company's legal counsel advised him that he was "subject to a blackout period and was prohibited from trading in CCE stock 'until further notice.' " Despite this directive, he is alleged to have purchased 15,000 CCE shares using his wife's brokerage account just prior to the public announcement of the acquisition. He was aware that the internal valuation of the acquisition was in the $800 million range.
In the particular trade that is the subject of the SEC's action, CCE's stock increased by 30 percent after the announcement of the acquisition. The SEC's complaint states that profits were gained in the amount of $86,850. In addition to disgorgement of these profits, the SEC seeks to prevent him from serving as an officer or director of a public company in the future. They also seek a permanent injunction enjoining him from future violations of the above-noted provisions of the federal securities laws.
The New York law firm of Gusrae Kaplan Nusbaum PLLC, represents brokers and traders before all regulatory agencies. Please contact our law firm to speak with one our experienced lawyers about representation and our litigation and advisory practice.
]]>The hope is that investors will understand and review their statements for such things as trades and fees, and will contact their broker if there is something they do not understand or do not believe they authorized. The Investor Alert also informs investors about reviewing their statements to ensure their investment goals and strategy are being carried out.
In other efforts to educate the public, the FINRA Investor Education Foundation's Military Spouse Fellowship Program has just announced its 2012 military spouse application process. The Securities Lawyer Blog has posted on this program in past years.
Military spouses have the opportunity to receive education and training on financial matters and to become an Accredited Financial Counselor. Many families benefit from this program, not only the spouses that receive the training, but those families that ultimately are counseled by other military member spouses that are trained in financial matters.
According to FINRA, "[s]pouse fellows have logged more than 306,000 hours helping military families reach their financial goals, and 314 spouse fellows have graduated from the program." The outreach includes such important areas as tax and credit counseling.
Finally, FINRA's Investor Education Foundation and United Way Worldwide (UWW) have recently announced the 12 grant recipients taking part in the Financial Education in Your Community effort, which is administered by the United Way Worldwide and the FINRA Investor Education Foundation. Over $1 million in funds has been disseminated to various grantees around the country.
Through this program, low- and middle-income families receive information on financial matters. This year's program includes agencies across the country from New York to Louisiana to Ohio and out to Seattle. Each grantee has a specific mission, but all are intended to educate youth and adults in various aspects of financial well being. A full list of grantees can be found by clicking here.
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Rule 14107(a) currently permits the parties to choose a mediator in one of two ways. They can either choose a mediator from FINRA's list that is provided by the Director, or they can choose a mediator using a list or other source provided by them. Generally, parties do choose a FINRA mediator from the FINRA roster, but they do not have to do so. Allowing parties to choose mediators from other sources increased the pool of mediators.
FINRA notes that over the 15 years in which this program has been in place, the mediator roster now includes "many seasoned securities mediators and selection of a non-FINRA mediator raises concerns for the forum." The application process to become a mediator is extensive and thorough and includes a lengthy screening and background review. The process also includes periodic evaluation of each mediator. Not only does FINRA staff screen each applicant, but the National Arbitration and Mediation Committee also reviews and approves every applicant prior to that applicant becoming a listed mediator.
In the proposed rule change, FINRA seeks to provide the Director with the discretion to deny the parties' mediator selection. The proposed amended Rule 14107(a) would still allow the parties to jointly propose a mediator from a different source or list, but the Director's approval would need to be obtained prior to the mediator's selection. In the event that the Director rejects the parties' request, they would be at liberty to select a mediator from FINRA's list of approved mediators. Alternatively, the parties could propose another mediator that is not on FINRA's list subject to the Director's approval for that mediator. The parties can also choose to mediate in a different forum.
According to FINRA, the intention for this proposed rule change is to support the mandate that FINRA rules be "designed to prevent fraudulent and manipulative acts and practices, to promote just and equitable principles of trade, and, in general, to protect investors and the public interest." The quality and integrity of the mediation program is said by FINRA to be supported by this proposal.
Public comment procedures are delineated in the proposed rule change, which also includes some housekeeping and related amendments.
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]]>The entities and individual are charged with securities fraud for allegedly "defrauding at least 23 investors out of $1.6 million in a series of Ponzi schemes." The allegations include the claim that the individual involved made direct and Internet solicitations from potential investors.
In the case of investors in Covenant Capital, the investing public was told that the investment was in real estate loans secured by deeds of trust. In the case of the investors who participated in Verde Retirement, the charged individual purported to be investing their money in either real estate loans secured by deeds of trust or certificates of deposit. In the case of the investors in Verde FX, the individual solicited investments telling potential investors that their investment would be pooled for investment in the construction of a distribution facility for FedEx in Las Vegas, Nevada.
According to the SEC's complaint, Hamilton never placed any investor money in real estate loans secured by deeds of trust, certificates of deposit or a FedEx facility. Instead, Hamilton used the $1.6 million he raised to pay his personal living expenses and return capital to investors.
Specifically, the complaint alleges that the representations to investors were materially misleading. Rather than using the money to invest in legitimate offerings, the offerings were fraudulent and "in order to perpetuate his scheme, and to make his purported investments appear successful" the individual charged is claimed to have used a portion of the monies raised "to pay fictitious returns to investors when, in fact, his investments were non-existent and he was simply using investors' monies to pay other investors." The SEC seeks a permanent injunction against Verde Retirement, Verde FX, Covenant Capital, and the individual as well as disgorgement, prejudgment interest, and a civil penalty against him.
Wall Street's Gusrae Kaplan Nusbaum PLLC represents broker-dealers in regulatory and enforcement matters. We regularly advise clients and defend industry members before all regulatory entities in matters involving a broad spectrum of issues for broker-dealers and firms. Contact our law firm to consult with one of our attorneys and to learn more about our law practice.
The individual involved and his company, Broadband Research Corporation (Broadband), have been charged with violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5. The action seeks disgorgement, monetary penalties and a permanent injunction against future violations. The individual involved has also been charged in a parallel proceeding with one count of securities fraud and one count of wire fraud.
This action is the result of ongoing investigative work by the SEC in the area of expert networks. According to the SEC, a total of 22 defendants have now been charged in enforcement actions that are the result of the agency's investigations into expert networks. This effort has resulted in the discovery of what is said to be "widespread insider trading at several hedge funds and other investment advisory firms."
Specifically, the agency states that it has uncovered insider trading related to a number of technology company's securities. The illicit gains total nearly $110 million from trading involving the securities of such high-profile technology companies as Apple, Dell, Fairchild Semiconductor, Marvell Technology and Western Digital.
In the case against Broadband, the company and its principal are alleged to have held themselves out as being in the business of providing legitimate research for investors interested in publicly traded tech securities. Rather than providing this research, the company is said to have provided material nonpublic tips that were "obtained from prohibited sources inside the companies."
The SEC claims that once the insider information was disseminated to clients of the firm, they traded on it while various hedge fund and investment advisers and managers in turn paid the principal and Broadband large consulting fees. Broadband's principal is alleged to have compensated his sources directly.
Gusrae Kaplan Nusbaum PLLC represents firms and broker-dealers in regulatory and enforcement matters. Our lawyers advise clients and defend industry members in matters involving a broad spectrum of issues and allegations including, market timing, sales practices, NASD Rule 3070 issues, Forms U4 and U5 reporting, front running, insider trading, market manipulation, trading issues and many other areas of regulation and enforcement. Please contact our law firm to consult with one of our attorneys regarding any area of our practice.
The firm established a bonus program after the merger that was intended to retain registered representatives who were high-producers. Participants in the bonus program were required to sign a promissory note related to these bonuses, that forced them to resolve disputes with the firm in the state courts, rather than in arbitration proceedings. FINRA found that the way this program was structured, employees could secure unpaid bonuses only by litigating in the courts. This effectively avoided the applicable arbitration rules that require disputes between firms and associated persons be arbitrated when they arise out of the business activities of the firm or associated person.
Specifically, in early 2009, the firm paid $2.8 billion to 5,000 registered representatives in retention bonuses. The bonuses were in the form of promissory notes which as previously noted, required the registered representatives to litigate any issues related to these bonuses in the state courts. This was said by FINRA to place a limitation on "the ability of defendants to assert counterclaims in such actions."
In addition to the issues relating to the forum in which disputes involving the promissory notes could be resolved, FINRA also alleged that the firm used Merrill Lynch International Finance, Inc. (MLIFI), a non-registered affiliate, rather than Merrill Lynch itself, as the source of the bonus payments. This was intended to enable MLIFI to file expedited hearings in New York state courts with regard to the promissory notes and was allegedly structured to avoid the requirement that the firm arbitrate disputes.
When many registered representatives left Merrill Lynch in late 2009, but did not pay back their loans under these agreements, the firm filed for expedited hearings in New York state court for recovery under these notes. This was alleged by FINRA to have directly violated FINRA rules requiring arbitration, as well as making it impossible for the registered representatives to assert potential counterclaims with regard to the bonuses.
The New York firm of Gusrae Kaplan Nusbaum PLLC advises broker-dealers and firms in all aspects of regulatory compliance. Our skilled and experienced lawyers represent industry members before all regulatory entities. Contact our law firm to consult with one of our attorneys.
]]>At first glance, the scenario is similar to other email scams, but these attacks differ in a significant way. In past instances, customers are sent emails asking for private information that is then used to fraudulently obtain information that allows outsiders to gain access to accounts.
As noted in the Regulatory Notice executive summary, the scheme has several steps that make it appear that the transfer requests are legitimate. But in fact the perpetrators have gained access to an investor's email and contact lists and that information is then used to instruct firms to make transfers into accounts controlled by third parties, not the investor. In some instances, these fraudulent "instructions" might include what are also fraudulent letters of authorization that attempt to pressure firms into releasing funds prior to a follow-up phone authorization.
The FINRA warning is intended to inform the public to avoid these circumstances by safeguarding assets. The Regulatory Notice is also intended to halt this trend by helping firms understand that allowing or accepting email instructions is fraught with risk. The hope is that firms will reassess their policies with regard to instructions, which should help protect against this fraudulent practice on the part of hackers.
Once an individual is aware of or suspects that email has been compromised, FINRA is asking that investors immediately inform their brokerage firms or financial institutions of this problem.
Referring generally to NASD Rule 3012 and NYSE Rule 401, RN12-05 reminds firms that they must establish, maintain and enforce written supervisory control policies and procedures that are reasonably designed to review and monitor the transmittal of funds or securities from customer accounts to third-party accounts. These requirements and their scope have been delineated in Regulatory Notice 09-64, which "highlighted a number of questions firms should consider in assessing the adequacy of their policies and procedures for verifying the validity of requests to withdraw or transfer customer funds."
This increase of fraudulent email activity serves as a reminder that firms should be vigilant in assessing and establishing policies and practices as to electronic communications with investors. Assessing the risks involved with the way in which investors are permitted to communicate instructions for the withdrawal or transfer of funds through electronic means, including verification and follow-up, are recommended.
The lawyers of Wall Street's Gusrae Kaplan Nusbaum PLLC are experienced advisors to firms and broker-dealers in all areas of compliance. Contact our law firm for more information on our wide range of services, including litigation and enforcement representation. We are a firm comprised of experienced former senior level regulators and securities and compliance litigators, providing advisory services to our clients in regulatory compliance.
Conflict of interest allegations can arise in various circumstances in the securities industry. Earlier this month, Citigroup Global Markets, Inc., settled conflict of interest allegations with the Financial Industry Regulatory Authority (FINRA) that arose in the context of research reports and research analyst's public appearances. The firm has agreed to pay $725,000 for the resolution of the allegations against it.
FINRA claimed that Citigroup did not disclose potential conflicts of interest that were relevant to business relationships that it maintained. At issue in the matter were research reports that the firm published from early 2007 through the first quarter of 2010. Part of the problem was alleged by FINRA to have been due to supervisory failures that otherwise might have caught the lack of required disclosures.
Additional allegations made by FINRA in this situation related to several issues. First, the firm did not disclose its management or co-management of public securities offerings; second, the firm did not disclose that it made a market in the securities of, and/or had a one percent or greater beneficial ownership in, covered companies from which it received revenues, and; third, the firm failed to disclose this in research reports.
Added to these allegations is the claim by FINRA that in public appearances, research analysts did not disclose potential conflicts when allegedly conflicted companies were discussed. According to FINRA's Executive Vice President and Chief of Enforcement, Brad Bennett, these alleged failures " 'prevented investors from being aware of potential biases in its research recommendations.' "
A major factor in the disclosure failures was stated by FINRA to be problematic databases that were used by the firm to manage and identify conflicts of interest. In this case, as in many others we have posted in the past, the databases were claimed to have been either inaccurate and/or incomplete. These database problems are alleged to have derived from what were deemed to be "technical deficiencies."
Wall Street's Gusrae Kaplan Nusbaum PLLC represents broker-dealers in regulatory and enforcement matters. We regularly advise clients and defend industry members before all regulatory entities in matters involving a broad spectrum of issues for broker-dealers and firms. These issues include maintaining adequate supervision and providing marketing materials that properly disclose potential conflicts of interest. Contact our law firm to consult with one of our attorneys and to learn more about our law practice.
]]>Perhaps a lesser-known business model for most of the investing public, life settlements involve the buying and selling of fractional interests in life insurance policies. Key to the offering of this investment is the insured's life expectancy, as well as the terms and conditions of the insurance policy.
In this matter, the SEC complaint alleges that three of the company's executives - the chairman and CEO, the president and general counsel and the chief financial officer -- " 'misled shareholders by failing to disclose a significant risk to Life Partners' business: the company was systematically and materially underestimating the life expectancy estimates it used to price transactions.' " These estimates are significant because if they are consistently inaccurate, the company's revenues and profits are likely to be adversely impacted.
The SEC also alleges that the company and its executives engaged in disclosure violations. They are also alleged to have engaged in improper accounting practices, which resulted in an overvaluing of the company's assets while also making it seem to the public that the company had healthy earnings from brokering these life settlement transactions. The company's misrepresentations and disclosure failures in its SEC public filings are alleged by the agency to have constituted a material risk to the company's revenues, which was detrimental to its shareholders and the investing public.
A major factor in this was the use of an allegedly unqualified individual to perform the actuarial work needed to estimate life expectancies, which were consistently shorter than they should have been. According to the complaint filed by the SEC, the shortened life expectancy valuations resulted in the use of material non-public information that generated revenues to the public's detriment. The person performing this function was not an experienced life expectancy underwriter and was told simply to use methodologies that had been established by a former underwriter that had worked for the company. The use of unqualified experts in a core valuation that is critical to a company's health, presents a risk to the investing public.
New York City's Gusrae Kaplan Nusbaum PLLC, represents firms and broker-dealers before all regulatory agencies. Please contact our law firm for a confidential consultation with one of our lawyers regarding representation and our litigation and advisory practice. Our highly-respected lawyers have decades of experience and expertise representing firms and broker-dealers.
One major area of focus this past year for FINRA has been its securities firm examination program. Several key reforms were made to "better detect potential fraud and to focus on areas of risk." To this end, FINRA conducted more than 3,050 examinations in 2011 and deployed the resources needed to accomplish these examinations. For example, matters that pose the most risk to investors are now designated as urgent, with resources allocated to expedite the review of these matters. One area in which this has been evident is in the staffing of district offices, which has increased to manage the push for greater real-time monitoring.
As noted in our last post, branch-level examinations are increasing, as are point-of-sale examinations. The shift this past year included greater time in the branch offices for FINRA staff -- another way in which resources were allocated in a different way than they have been in the past. This is borne out by the numbers, as FINRA reported an increase of 350 more branch office exams than in the past year. This is a significant increase that is likely continue into 2012.
Another major area of significant expansion for FINRA was in equity markets regulation. FINRA took over the primary surveillance of the NYSE's equity and options markets, and according to the agency its collection of data is now accounting for 80 percent of volume across the NASDAQ and NYSE.
New developments for 2012 include the creation of comprehensive cross-market surveillance patterns which will be evaluating trading activity across these markets simultaneously. According to FINRA, the "consolidation of market data for integration into new cross-market surveillance patterns will help FINRA identify problematic trading activity more quickly." The intention is to "detect improper conduct" as soon as possible and then take steps to stop it from continuing. In addition, the NYSE's Order Tracking System is essentially being replaced as FINRA has now expanded its tracking systems to meet its cross-markets surveillance responsibilities.
Arbitration panel composition was another area of change for FINRA, with nearly 4.400 arbitration matters filed last year. As we posted last year, FINRA's new arbitration rule made it possible for customers with three panel arbitrations to have those panels comprised of only public members. This was intended to support the public's confidence in the arbitration process.
Finally, FINRA notes that its Investor Education Foundation issued investor alerts on a number of topics. We have posted information about some of these alerts this past year, which are intended to educate the public on various issues, including potential scams and high-risk investments.
The New York firm of Gusrae Kaplan Nusbaum PLLC represents firms and broker-dealers in regulatory and enforcement matters. Our lawyers advise our industry member clients in matters involving a broad spectrum of issues before all regulatory entities. Contact our law firm to consult with one of our attorneys.