Defending FINRA Disciplinary Matters: The CSG Law Securities Enforcement Group
1. FINRA Enforcement Defense
Chiesa Shahinian & Giantomasi PC (CSG Law) represents registered representatives, associated persons, broker-dealers, investment advisers, senior executives, and financial services professionals in FINRA examinations, investigations, enforcement actions, and disciplinary proceedings.
The CSG Law Securities Enforcement Group is led by two former senior FINRA Enforcement leaders: Christopher J. Kelly, former Senior Vice President, Deputy Head of Enforcement, and Acting Head of Enforcement at FINRA, and Lisa M. Colone, former Vice President – Enforcement Legal at FINRA. Together, Mr. Kelly and Ms. Colone bring in-depth regulatory experience and insight gained from overseeing thousands of FINRA enforcement investigations.
Contact us for additional information on how we can assist you with any of your needs.
2. How CSG Law Helps in FINRA Investigations and Disciplinary Proceedings
The CSG Law Securities Enforcement Group assists clients with every stage of a FINRA investigation or disciplinary matter, including:
- Responding to FINRA Rule 8210 requests for documents and information;
- Preparing clients for on-the-record (OTR) testimony;
- Advising on and drafting Wells submissions;
- Defending FINRA disciplinary proceedings and hearings; and
- Managing parallel SEC, DOJ, state securities regulatory, and internal investigations
3. Proven Results in Securities Enforcement Defense
The CSG Law Securities Enforcement Group has favorably resolved FINRA matters for registered representatives, associated persons, and other financial services professionals involving allegations of:
- Fraud and insider trading;
- Sales practice, suitability, and Regulation Best Interest (Reg BI) issues;
- Market manipulation and trading practices;
- Outside business activities (OBAs) and private securities transactions (PSTs);
- Form U4 reporting; and
- Failure to supervise and compliance breakdowns.
Representative matters include:
- Resolved a FINRA investigation of broker-dealer co-executives involving alleged private securities transactions with cautionary letters only.
- Resolved a FINRA investigation of a registered representative concerning alleged misrepresentations in the sale of private placements with a cautionary letter only.
- Resolved a FINRA investigation of several registered representatives concerning allegedly unsuitable sales of variable annuities with cautionary letters only.
- Resolved a FINRA investigation of a broker concerning allegedly unsuitable sales of variable insurance products with a cautionary letter only.
- Resolved a FINRA investigation of a securities trader concerning market manipulation allegations with a cautionary letter only.
- Resolved a FINRA investigation of a broker concerning allegedly insider trading with no further action.
- Resolved a FINRA investigation of a broker concerning alleged Reg BI violations involving corporate bond recommendations and margin trading with no further action.
*Results may vary depending on your particular facts and legal circumstances.
4. When to Contact a FINRA Enforcement Defense Lawyer
It can be difficult to know when to contact an attorney experienced in FINRA investigations and disciplinary matters, especially because FINRA staff do not always disclose the scope or purpose of an inquiry. Registered representatives and associated persons should strongly consider consulting a FINRA enforcement defense lawyer if they have:
- Received a customer complaint;
- Received a “lawyer’s letter” from an attorney representing a current or former customer;
- Been named in a FINRA arbitration;
- Been contacted by a FINRA staff member and asked to provide information, even informally;
- Received a written request for documents or information pursuant to FINRA Rule 8210;
- Received a notice from FINRA seeking to take on-the-record (OTR) testimony;
- Received a Wells Notice from FINRA staff; or
- Been the subject of an internal investigation by their employing broker-dealer.
Even seemingly routine FINRA requests can lead to lengthy investigations and, in some cases, formal disciplinary action. Early legal guidance can help preserve defenses, manage risk, and position the matter for the best possible outcome.
5. Securities Enforcement Resources
Delving into their unique and extensive knowledge of the inner workings of FINRA, as well as the other regulatory bodies that govern the financial services industry, the CSG Law Securities Enforcement Group provides valuable analyses of timely trends, themes, and lessons learned at recent speaking engagements and in their thought-leadership pieces.
Click here to view the Group’s latest news, publications, and events.