The Neutral Corner - Volume 3 - 2008
By Judith R. Starr *
Introduction by Alma Angotti **
On October 26, 2001, President George W. Bush signed into law the USA PATRIOT Act (Patriot Act). Title III of the Patriot Act, entitled "International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001," added several new provisions to the Bank Secrecy Act, many of which expanded the statute's application to broker-dealers.
One of the most important additions from the Patriot Act required the Department of the Treasury (Treasury) to issue rules requiring broker-dealers to file suspicious activity reports (SARs) with the Treasury's Financial Crimes Enforcement Network or FinCEN. On July 1, 2002, the Treasury published its final rule, requiring broker-dealers to file reports identifying transactions occurring after December 30, 2002 that raise suspicions of illegal activity.
Statistics published by FinCEN, in Issue 9 of SAR Activity Review by the Numbers (February 2008), show that the broker-dealer community is taking its responsibility to file reports of suspicious activity seriously. The total number of SARs has steadily increased from 4,267 filed for 2003 to 5,984 SARs filed in the first 6 months of 2007. The statistics indicate that broker-dealers are focusing on securities fraud and related issues in their monitoring and reporting of suspicious activity. For example, SARs filed for market manipulation have increased from 27 reports in 2003 to 734 reports in the first six months of 2007. Similarly, reports filed for securities fraud increased from 143 SARs in 2003 to 696 SARs between January and June 2007.
With more SARs filed every year, the securities industry and financial regulators must preserve the confidentiality of these reports, which is so vital to law enforcement efforts to protect the U.S. financial system from criminal abuse. With that in mind, FINRA is republishing an important article by Judith R. Starr, who was the Chief Counsel of FinCEN at the time of the article's original publication in The Neutral Corner (June 2005). The article reminds us that SARs and communications that show the existence of a SAR are absolutely privileged and cannot be disclosed, in either litigation or in arbitration.
Guidance for Arbitrators on Requests to Produce Suspicious Activity Report Information (Republished from the June 2005 issue of The Neutral Corner)
Since January 1, 2003, broker-dealers have been required to file suspicious activity reports (SARs) with the Department of Treasury's Financial Crimes Enforcement Network (FinCEN). These reports, mandated by the Bank Secrecy Act—a law that imposes reporting, recordkeeping, and anti-money laundering program requirements on financial institutions—are an important tool in the federal government's fight against financial crime and the financing of terrorism.1 This article explains the privilege that applies to SARs, and provides guidance to arbitrators on dealing with requests to obtain such information from a broker-dealer.
Background on SARs
FinCEN administers the Bank Secrecy Act and, under its authority, has issued the rule requiring broker-dealers to report suspicious activity. FinCEN's SAR rule requires a broker-dealer to file a SAR if it "knows, suspects or has reason to suspect" that a transaction involving at least $5,000 conducted or attempted to be conducted through the broker-dealer: (1) involves funds from illegal activity; (2) is designed to evade reporting requirements; (3) has no business or apparent lawful purpose, or is not typical of the customer and the broker-dealer knows of no reasonable explanation for it; or (4) involves use of the broker-dealer to facilitate criminal activity.2 SARs and other Bank Secrecy Act reports are part of a government-wide data network maintained by FinCEN to support the investigation of financial crime and terrorism. FinCEN shares SAR information with other agencies for criminal, tax, regulatory, and counter-terrorism purposes.
Congress recognized that protection of the sensitive financial information in SARs—and the very act of a financial institution's filing a SAR—was necessary to encourage robust reporting of suspicious activity while protecting privacy interests and the confidentiality of law enforcement investigations. Therefore, the Bank Secrecy Act provides an unqualified privilege against compelled disclosure of SARs or of documents or testimony relating to their filing.3 The statute prohibits any financial institution, and its officers, directors, employees, or agents, from notifying any person involved in a transaction that the transaction has been reported. FinCEN's broker-dealer SAR rule further provides that any person subpoenaed or otherwise requested to disclose a SAR or information contained in it (except where disclosure is requested by law enforcement or the firm's regulator) shall decline to produce a SAR or disclose any information that a SAR has been prepared and filed, and notify FinCEN of the demand.
To further encourage financial institutions to file SARs, Congress also provided them with a “safe harbor” from liability. The statute protects financial institutions and their agents from liability to any person under state, federal, or local law, or under a contract, including an arbitration agreement, as a result of filing a SAR or failing to disclose the filing of the SAR.
Although the broker-dealer SAR rule is too new to have generated reported decisions, the bank SAR rules issued by FinCEN and the federal banking regulators, which both contain substantially identical disclosure prohibitions, have existed since 1996, and have generated a number of decisions. The disclosure prohibitions of the statute and rules, combined with the safe harbor, led courts to conclude that Congress did not intend to permit them to order the disclosure of SARs.4 In finding SARs to be absolutely privileged, courts also cited the harm from compelled disclosure, including tipping off criminals, revealing methods for detecting suspicious activity, and imperiling employees who make the reports.5
The protection from compelled disclosure extends beyond the SAR itself. Otherwise, compelled testimony from SAR preparers about the SAR, or production of documents disclosing a filer's communications with law enforcement about the SAR, could be used to subvert the disclosure bar. In a recent case, a litigant disclaimed interest in obtaining a SAR of which he allegedly was the subject, but sought communications between a bank and law enforcement about the matter. The court found that such communications fell within the scope of the privilege for SARs. Specifically, the court identified five types of communications protected by the privilege:
Arbitrators and Requests for SARs
Arbitrators are likely to face requests for orders to produce SARs, or testimony or communications about them, in one of two fact patterns. An alleged subject of a SAR may be making a claim or asserting a counter-claim against a firm arising from the alleged filing; or the victim of unlawful activity that may be reflected in a SAR seeks to obtain any SAR filed on the activity to support the victim's case against the firm or an associated person. How should such requests be handled?
Broker-dealers and their agents are not permitted to reveal the existence of a SAR. Therefore, questions about reports to government agencies of suspected illegal activities should not be permitted. (Note that this prohibition does not extend to required filings with the SROs and the Securities and Exchange Commission (SEC), such as a Form U-4, which have a special exception from the SAR reporting requirement so as to avoid duplicative reporting.) The production of SARs should never be required, and documents generated through a firm's SAR review process, both pre- and post-filing (or documents relating to a decision not to file), should not be subject to a disclosure order. An arbitrator should not permit a party to elicit testimony concerning communications to law enforcement about suspected illegal activity. As noted above, the underlying business records, including account statements and transactional records, are not subject to the privilege. However, questioning about the activity reflected in such unprivileged documents should not be allowed to expand into questioning concerning the reporting of such activity.
One must protect the confidentiality of SARs in an arbitration. The production of a SAR or SAR information in an arbitration would harm a system that both Congress and the agency responsible for administering the authorizing statute have determined requires the existence of an unqualified privilege in order to achieve its aims.
|*||Judith R. Starr is currently general counsel for the Pension Benefit Guaranty Corporation. From December 2001 to July 2005, she was the Chief Counsel of FinCEN, serving as its chief legal officer and supervising its legal staff. Before joining FinCEN, she spent ten years at the SEC as Assistant Chief Litigation Counsel in the Division of Enforcement, and as an appellate attorney in the Office of General Counsel. She received the Stanley Sporkin Award for outstanding contributions to securities law enforcement in 1999, and was appointed to be a special prosecutor in the criminal contempt case against stock manipulator Robert Brennan by the United States District Court for the Southern District of New York. Ms. Starr was a commercial litigator in Los Angeles before joining the SEC. She is a graduate of Harvard Law School and the College of William and Mary.|
The views expressed herein are those of the author and do not necessarily represent the views of FinCEN or the Department of the Treasury.
|**||Alma Angotti is a Senior Counsel in FINRA's Department of Enforcement. She also serves as a FINRA regulatory expert for Anti-Money Laundering (AML) and is involved in most aspects of interpretation and enforcement of AML regulations and SRO rules. She is involved in designing and conducting AML training for FINRA staff and the financial services industry, both domestically and internationally. She participates as a FINRA representative to several inter-agency AML groups and is a frequent speaker on AML issues.|
|1||The Bank Secrecy Act is codified at 31 U.S.C. 5311-32. The SAR provisions are in section 5318(g).
|2||FinCEN's broker-dealer SAR rule is codified at 31 CFR 103.19. To avoid duplicative filings, there is an exception to the reporting requirement for reports of securities violations that must be made by the firm itself or an associated person to the SEC or an SRO, such as the filing of a Form U-4 or U-5.
|3||Whitney National Bank v. Karam, 306 F. Supp.2d 678 (S.D. Tex. 2004).
|4||See Lee v. Bankers Trust Co.,166 F.3d 540 (2d Cir. 1999); Weil v. Long Island Savings Bank, 195 F. Supp.2d 383 (E.D.N.Y. 2001).
|5||See Cotton v. Privatebank and Trust Co., 235 F. Supp. 809 (N.D. Ill. 2002).
|6||Whitney v. Karam, supra note 3.|
Arbitration case filings from January through March 2008 reflect a 9 percent increase compared to cases filed during the same three-month period in 2007 (from 825 cases in 2007 to 899 cases in 2008).
Neutral Roster Call-In Workshops
March 13, 2008: What Neutrals Should Know
On March 13, FINRA Dispute Resolution conducted a call-in workshop for neutrals. Almost 1,230 arbitrators and mediators listened to the live broadcast and nearly 500 neutrals listened to the audio recording posted on our Web site. Linda Fienberg, President of FINRA Dispute Resolution, provided an update on recent rule filings and Dispute Resolution developments and trends. George Friedman, Executive Vice President and Director of FINRA Dispute Resolution, moderated a discussion with members of FINRA's Office of General Counsel: John Flood, Vice President and Associate General Counsel, and Sarah Gill, Senior Attorney. They addressed electronic discovery, steps neutrals should take to avoid post-arbitration litigation and what neutrals should do if they are named in a lawsuit. If you missed the workshop, you may listen to a recording (MP3 File, 6.5 MB) . You may also download the presentation materials used during the workshop titled, "What FINRA Arbitrators and Mediators Should Know: Litigation Issues (PDF 6 MB)."
June 19, 2008: Experienced Neutrals Present: Best Practices for Handling Difficult Situations
FINRA polled neutrals who participated in the November 6, 2007 call-in workshop to learn what topics they would like addressed in upcoming workshops. Many respondents to the survey requested that we conduct a workshop on best practices for running efficient hearings and handling difficult participants. In response to your feedback, FINRA will host a call-in workshop on June 19, 2008 from 1 to 2 p.m. ET entitled "Experienced Neutrals Present: Best Practices for Handling Difficult Situations." In addition to updates on current developments in Dispute Resolution, George Friedman will moderate a discussion with two experienced neutrals—Constantine Katsoris, Wilkinson Professor of Law at Fordham Law School, and David Robbins, a partner in the law firm Kaufmann, Feiner, Yamin, Gildin & Robbins LLP. Using real-life scenarios, the faculty will discuss best practices for arbitrators in handling difficult situations during an arbitration proceeding.
We encourage you to submit scenarios for our experienced neutrals to consider for the workshop. Send your suggestions through email.
FINRA will hold its 2008 Spring Securities Conference on May 21-23 in Hollywood, Florida. This conference will provide comprehensive updates on securities industry rules, regulations and compliance issues. FINRA staff and other regulators and industry representatives will address regulatory updates and facilitate a wide range of workshops.
During the Conference, Dispute Resolution will conduct a workshop on the basics of arbitration using a hypothetical arbitration claim. Presenting this highly interactive program will be: Linda Fienberg; George Friedman; Garry O'Donnell, FINRA Arbitrator; Melanie S. Cherdack of the law firm Genovese Joblove & Battista, P.A.; and Richard L. Martens of the law firm Casey Ciklin Lubitz Martens & O'Connell.
Continuing Professional Education (CPE) and Continuing Legal Education (CLE) credits are available for FINRA's Spring Securities Conference. Please indicate on the registration form if you wish to receive CPE and/or CLE credit.
Alternative Dispute Resolution (ADR) Program for Minority Professionals
From June 2-6, 2008, Capital University Law School will sponsor the 3rd National Training Institute of Minority Professionals in Alternative Dispute Resolution in Columbus, Ohio. The purpose of the conference is to promote opportunities and eliminate barriers for minority ADR professionals by offering affordable, high-quality training to expand skills in negotiation, mediation, facilitation and arbitration; to provide greater access to the ADR marketplace; and to prepare participants for advancement within the field of ADR. This conference also provides great networking and informational opportunities.
On June 4 from 1 to 5 p.m., FINRA will conduct an onsite Basic Arbitrator Training program. Please visit Capital University's Web site for additional information about this conference.
Amendments to the Chairperson Eligibility Rule
On March 12, 2008, FINRA filed proposal SR-FINRA-2008-009 with the SEC to amend the chairperson eligibility requirements under Rule 12400(c) of the Customer Code and Rule 13400(c) of the Industry Code. FINRA is proposing to remove the "substantially equivalent training or experience" criterion from the rules to make the chairperson eligibility standards more objective and uniform.
Find more information on this proposal.
Proposing Rules to Address Expungement Relief Requests
On March 13, 2008, FINRA filed proposal SR-FINRA-2008-010 with the SEC to adopt Rule 12805 of the Customer Code and Rule 13805 of the Industry Code. If approved, these rules will establish new procedures that arbitrators must follow when considering requests for expungement relief under NASD Conduct Rule 2130. The proposed rules will require arbitrators considering an expungement request to:
The new procedures are designed to: (1) make sure that arbitrators have the opportunity to consider the facts that support or oppose a decision to grant expungement and (2) ensure that expungement occurs only when the arbitrators find and document one of the narrow grounds specified in Rule 2130.
Find more information on this proposal.
Amendment to the Definition of Public Arbitrator
On March 13, 2008, the SEC approved SR-NASD-2007-021, which amends the definition of public arbitrator by adding an annual revenue limitation. Under the new rule, a person will not be classified as a public arbitrator if he/she is an attorney, accountant or other professional whose firm derived $50,000 or more in annual revenue in the past two years from professional services. This includes services rendered to any persons or entities involved in securities business relating to any customer disputes concerning an investment account or transaction, including but not limited to law firm fees, accounting firm fees and consulting fees.
The SEC published the Approval Order in the Federal Register on March 13, 2008. FINRA anticipates publishing a Regulatory Notice in May 2008 that will describe the proposal and how it will be applied.
FINRA is in the process of surveying the available public arbitrators on its roster to ensure that all are correctly classified when the new rule goes into effect. If you have not yet responded to the paper or email version of the survey, please do so at your earliest convenience. Those who do not respond by the time the Rule becomes effective will be made inactive on the roster.
Find the Approval Order and more information about the new rule.
Things may sound a little different at the end of your next FINRA arbitration hearing. We have incorporated two changes to the hearing scripts that relate to: (1) the parties' final damage requests; and (2) the closing of the hearing.
The first change is a result of our ongoing efforts to provide our constituents with as much information as possible about investors' recovery rates in our forum. During the course of discovery or the evidentiary hearing, parties may reduce their initial damage requests. Therefore, to add transparency to our process concerning the amount of damages claimed and the amount awarded, we amended the language arbitrators use to clarify damage requests from the parties.
The National Arbitration and Mediation Committee (NAMC) approved the following script language:
|“We realize that at the time the claim was initiated the parties may not have had all of the information needed to accurately or completely calculate their claims. Therefore, at this point, we ask that the parties restate their respective claims. For parties requesting damages, please provide us with a summary of your final request for damages. You may present your final damage request as a range, as opposed to a specific monetary amount.”
|Note to Arbitrators: If a party's final request for damages is different from the amount stated in its pleading, please record this amount in the Award Information Sheet item number 10.|
If a party's final damage request amount is different from what the party requested in an earlier pleading, then arbitrators will record the new amount on the Award Information Sheet. In addition to the parties' original requests as specified in their pleadings, these new final damage requests will be reflected in all awards.
Reminder Regarding Amendments
As a matter of right, parties may amend their pleadings, including adjustments to their damages requests, up until the time FINRA appoints a panel. Once a panel is appointed, parties may only amend their pleadings if the panel grants a motion to amend the pleading. We encourage you to review the Codes of Arbitration Procedure for Customer and Industry Disputes (Codes), Rules 12309 and 13309 respectively, for more information on amending pleadings.
Closing the Hearing
The second script change modifies the language that arbitrators use when closing the hearing. As part of the consolidation of NASD and NYSE's dispute resolution functions, we convened a working group of the NAMC to examine each forum's best practices, which included the use of different hearing scripts.
FINRA's hearing scripts formerly required arbitrators, before closing the hearing, to ask parties to state affirmatively whether they had a “full and fair” opportunity to be heard. However, the Codes do not require this language; nor did NYSE's hearing scripts.
The NAMC voted to replace the "full and fair" hearing language with the following language:
|“Do the parties have any other issues or objections that you would like to raise that you have not previously raised?”|
The revised language reminds arbitrators to ensure that the record is complete before they close the hearing.
These same changes have been made to the single arbitrator hearing script. You may find the updated hearing scripts, along with the most current information on arbitration procedures, in the Arbitrator's Reference Guide on our Web site. FINRA staff will also distribute the revised scripts to arbitrators as part of their case packets.
Question: What procedures should arbitrators follow if a party fails to appear at a prehearing conference or a hearing on the merits?
Answer: The procedures that arbitrators should follow depend upon the stage of the case. If a party fails to appear at the Initial Prehearing Conference, arbitrators should proceed with the conference with the other parties and establish hearing dates. The non-appearing party may request a postponement if the hearing dates pose a scheduling conflict. In the case of a non-appearing respondent, arbitrators should notify Dispute Resolution staff of the party's non-appearance and inquire about the following: whether service was perfected upon the respondent; whether mail was returned; and whether the mail was being sent to the respondent's address as listed on the Central Registration Depository (CRD).
Individuals associated with member firms have a duty to update their addresses on CRD; those individuals who have left the industry have a duty to update their addresses for a period of two years after leaving the industry. By familiarizing themselves with the status of the non-appearing party, arbitrators will be in a better position to make future decisions about how to proceed should the party again fail to appear. If arbitrators are aware that a party may not appear at a scheduled prehearing conference or hearing, they should contact Dispute Resolution staff prior to the scheduled conference or hearing to obtain an update on the party's status.
If a party who has never appeared then fails to appear at a subsequent prehearing conference, arbitrators should determine how they want to proceed. If the non-appearing party has previously participated in the matter, arbitrators should confirm that the party had notice of the prehearing conference before proceeding. In addition, if the prehearing conference is by telephone, arbitrators should verify the party's telephone number with the conference operator or Dispute Resolution staff.
If a party fails to appear at the hearing on the merits, arbitrators should notify Dispute Resolution staff of the party's non-appearance. With the help of the case administrator, arbitrators must review the file to determine whether the party was properly served with the Statement of Claim and notice of the hearing. If the arbitrators are satisfied that the non-appearing party received sufficient notice of the proceeding and of the appointed hearing date and time, they should proceed with the hearing with the remaining parties.
In the event a claimant fails to appear at a hearing, arbitrators should undertake the same review process in determining how to proceed with the arbitration.
Mediation Strategic Planning Process
In 2007, the Mediation Department commenced a strategic planning initiative to improve mediation services. We started by conducting focus groups with frequent forum users in different cities. Using the feedback gathered from the focus groups, we circulated an email survey to more than 600 party representatives active in our forum. We designed the survey to elicit responses from customers about what they like best about the current mediation services, what factors are important for selecting a mediator and what mediation service features they would want implemented in the future.
The survey ended on December 31, 2007 with over 120 people submitting responses. We are currently analyzing the results and will seek input from the National Arbitration Mediation Committee (NAMC) through its Mediation and Other Forms of ADR subcommittee (Mediation Subcommittee). Then, we will consider potential policy changes and adjustments to the program to help us continue to meet the needs of the parties, their representatives and our mediators.
Joining our roster is a highly competitive process. We prescreen potential applicants before asking them to complete the detailed application. The application and approval process is competitive because parties in our forum expect mediators with significant mediation experience, excellent reputations in the industry and relevant subject matter expertise. Once a mediator submits an application, we review it to make sure it is complete. Then, we summarize the applications and submit them with our recommendations to the Mediation Subcommittee for its review and final determination. The Mediation Subcommittee has three weeks to determine if it approves our recommendations.
Business Strategies Update
On March 7, 2008, Assistant Director William Kimme, along with Malcolm Northam and Paul Andrews of FINRA's International Group, gave a presentation to a delegation from the Ministry of Finance in Japan. This is part of FINRA's ongoing efforts to provide services internationally. The meeting arose out of a presentation that Mr. Kimme made to this same group about FINRA's dispute resolution services in February of 2007.
We are pleased to report that Shari Sturm, former Associate Vice President and Director of Constituent Relations for Dispute Resolution, has accepted a position in FINRA's Member Regulation Training Department. In this capacity, Shari will serve as the Training Manager, training new examiners in FINRA's Examiner University. We wish Shari much success in this new position.
Since joining Dispute Resolution in 1987, Shari has worked in a number of positions. During her tenure, she worked as a Staff Attorney in the Northeast Regional Office, was promoted to Senior Attorney, inaugurated our Washington, D.C. satellite office and later served as Director of the Mid-Atlantic Regional Office. Shari has been a strong contributor to Dispute Resolution's initiatives; most notably, she has done a tremendous job training arbitrators through our various programs. We thank Shari for her dedication to providing outstanding service to all of the users of our forum.
NOTE: Participants must successfully complete the online portion of the Basic Arbitrator Training Program before attending an onsite training program. Please visit the Arbitrator Training page for more information. FINRA generally requires a minimum of nine attendees to conduct an onsite session.
Northeast Regional Update
During the next three months, the Northeast Regional Office will conduct the following in-person Basic Arbitrator Training programs:
|Hartford, CT||May 13, 2008|
|New York, NY||June 4, 2008|
|Philadelphia, PA||July 16, 2008|
If you are interested in attending a Basic Arbitrator Training program in any of these locations, please contact Cicely Moise at (212) 858-3963 or through email.
Midwest Regional Update
During the next three months, the Midwest Regional Office will conduct the following in-person Basic Arbitrator Training programs:
|Chicago, IL||May 14, 2008|
|Cleveland, OH||June 18, 2008|
|Minneapolis, MN||July 16, 2008|
If you are interested in attending a Basic Panel Member Training program in any of these locations, please contact Deborah Woods at (312) 899-4431 or through email.
West Regional Update
During the next three months, the West Regional Office will conduct the following in-person Basic Arbitrator Training programs:
|Portland, OR||May 13, 2008|
|Salt Lake City, UT||June 12, 2008|
|Houston, TX||June 12, 2008|
|Denver, CO||July 15, 2008|
If you are interested in attending a Basic Arbitrator Training program in any of these locations, please contact David Newson at (213) 613-2693 or through email.
Southeast Regional Update
On February 25, 2008, George Friedman presented a lecture titled, “Ethical Obligations of the Tribunal,” to the Securities Committee of the South Palm Beach County Bar Association.
On February 27, 2008, the Southeast Regional Office hosted a focus group to discuss forum users' reactions to the new Code of Arbitration Procedure and the role of the non-public arbitrator in arbitration proceedings. Rose Schindler, Vice President and Director of the Southeast Regional Office, moderated a panel of party representatives and arbitrators to discuss these topics; Dispute Resolution senior staff was also in attendance.
On February 28, 2008, Kevin D. Rosen, Case Administration Manager, participated in a Public Interest/Public Sector Career Fair hosted by the University of Miami School of Law. Mr. Rosen spoke with law students about FINRA's arbitration and mediation programs.
During the next three months, the Southeast Regional Office will conduct the following in-person Basic Arbitrator Training programs:
|Birmingham, AL||May 20, 2008|
|Washington, DC||June 17, 2008|
If you are interested in attending a Basic Arbitrator Training program in any of these locations, please contact Lanette Cajigas at (561) 447-4911 or through email.
In addition to comments, feedback and questions regarding the material in this publication, we invite you to submit suggestions for articles and topics you would like addressed. We reserve the right to determine which articles to publish.
Please send your comments to:
Jisook Lee, Editor
The Neutral Corner
FINRA Dispute Resolution
One Liberty Plaza
165 Broadway, 27th Floor
New York, New York 10006
You may also email Jisook.
Linda D. Fienberg
George H. Friedman
Kenneth L. Andrichik
Jean I. Feeney
Richard W. Berry
Barbara L. Brady
Elizabeth R. Clancy
Judith Hale Norris
Associate Vice President
MATRICS DR Business
Associate Director of Neutral Management
Editor of The Neutral Corner
Julie Crotty - Mediation
Mignon McLemore - Office of Chief Counsel
Nene Ndem - Southeast Region
lanthe Philips - West Region
Patrick Walsh - Midwest Region
FINRA Dispute Resolution Offices
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