On March 26, 2020, EGS’ attorneys obtained non-reportable “cautionary action” letters on behalf of two clients in connection with related FINRA regulatory investigations. The matters involved allegations concerning the solicitation and payment of charitable donations by firm employees over a four year period to a charity related to a firm client.
Within the past year, EGS has successfully obtained other cautionary action letters from FINRA on behalf of its clients, including:
- Allegations of substantial steps in forming and initiating an outside business activity without firm disclosure or approval
- Allegations of affixing customer signatures onto an insurance policy delivery receipt and submitting it to the Firm for processing of the policy
- Allegations of failure to make timely disclosure of one or more reportable financial events
- Allegations of investing and raising funds for Broadway shows without detailed, written notice to the firm; public customer trading in triple leveraged ETFs with extended holding periods; the recommendation of a third-party investment manager that was barred by the SEC; and causing the forfeiture of variable annuity rider benefits
EGS also obtained a cautionary letter on behalf of a client from the State of Washington, Department of Financial Institutions, Securities Division concerning the recommendation of C-share mutual funds to clients and not availing clients of breakpoint discounts.
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For more information about EGS’ securities enforcement practice, please contact David A. Gehn, Esq. (dgehn@egsllp.com) or Matthew B. Baum, Esq. (mbaum@egsllp.com).
