To inform readers of new FINRA Rule 2165 and amended FINRA Rule 4512, which are aimed at protecting seniors from financial exploitation.
This article discusses the scope of the FINRA Rules and amendments, including provisions for temporary holds on disbursements of funds or securities and the revised National Adjudicatory Council (NAC) Sanction Guidelines, and provides the author’s analysis.
This article concludes that the while FINRA Rule 2165 and the accompanying amendments to FINRA Rule 4512 take the apparent position that financial professionals are an initial line of defense against exploitation, brokers could face challenges in implementing the changes, including with the decision-making discretion afforded to them with respect to the “reasonable belief” elements of the rules.
This article contains valuable information about recent FINRA Rules and guidance from an experienced investment management lawyer.
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