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May 19, 2011
Reprinted with permission from Law360
In an article published this week by Law360, Sutherland Partner Brian Rubin and Associate Andrew McCormick attempt to answer that question. Every year, broker-dealers and registered representatives focus on FINRA's Regulatory and Examination Priorities Letters to learn what types of subjects and cases FINRA intends to pursue. In their article titled "Does FINRA Accurately Seed Enforcement Issues?" Rubin and McCormick compare the Exam Priorities Letters from 2007 and 2008 with enforcement actions from 2009 and 2010 to see whether FINRA's stated examination priorities actually lead to enforcement actions in those areas.