The D.C. Circuit has held that FINRA may not expel a member firm, Alpine Securities, in an expedited proceeding before Alpine obtained full review by the SEC of the merits of any expulsion decision or before the period for Alpine to seek such review had elapsed.
In an article for Law360, partners Jan Folena and Gregory DiMeglio, co-chairs of the securities enforcement practice, and managing counsel Lara Burke delve into the court’s opinion and what it might mean for FINRA’s enforcement and other non-governmental disciplinary programs going forward.
Read the expert analysis on Law360 (with a subscription).