Adjudication and Decisions

When FINRA determines that violations of securities rules have occurred and formal disciplinary action is necessary, the Enforcement Department or Market Regulation Department files a complaint with the Office of Hearing Officers (OHO).

The Office arranges a three-person panel to hear the case. The panel is chaired by a hearing officer who is an employee of the Office of Hearing Officers. The Chief Hearing Officer appoints two industry panelists, drawn primarily from a pool of current and former securities industry members of FINRA's District Committees, as well as its Market Regulation Committee, former members of FINRA's National Adjudicatory Council (NAC) and former FINRA Governors.

At the hearing, the parties present evidence for the panel to determine whether a firm or individual has engaged in conduct that violates FINRA rules, SEC regulations or federal securities laws. In reaching its decision, the hearing panel also considers previous court, SEC, and NAC decisions to determine if violations occurred. The NAC is the national committee which reviews initial decisions rendered in FINRA disciplinary and membership proceedings.

For each case, the hearing panel will issue a written decision explaining the reasons for its ruling and consult the FINRA Sanction Guidelines to determine the appropriate sanctions if violations have occurred. FINRA also, when feasible and appropriate, can order firms and individuals to make restitution to harmed customers.

Appeals Process

Under FINRA's disciplinary procedures, a firm or individual has the right to appeal a hearing panel decision to the NAC, or the NAC may on its own initiate a review of a decision. On appeal, the NAC will determine if a hearing panel's findings were legally correct, factually supported and consistent with FINRA's Sanction Guidelines. While a panel decision is on appeal, the sanction is not enforced against the firm or individual.

Unless FINRA's Board of Governors decides to review the NAC's appellate decision, that decision represents FINRA's final action. A firm or individual can appeal FINRA's decision to the SEC and then to federal court.

Date of Decision Proceeding No. Titlesort ascending Type
Jul 21, 2011 200801201960 Rebecca Amy Reichman Disciplinary Decision
Jun 17, 2016 SD-2026 RBS Securities, Inc. Statutory Disqualification
Jan 31, 2014 SD-1794 RBC Capital Markets, LLC Statutory Disqualification
Aug 5, 2014 2011027402201 CALLED FOR REVIEW: Raymond Thomas Clark Disciplinary Decision
Oct 5, 2015 2009017899801 APPEALED: Rani T. Jarkas Disciplinary Decision
May 25, 2005 C10030110 Ram Kapara Disciplinary Decision
Feb 16, 2007 E072004044201 Ralph Merhi Disciplinary Decision
Feb 21, 2006 C9B030076 Raghavan Sathianathan Disciplinary Decision
Jun 12, 1998 C10930017 Rafael Pinchas Disciplinary Decision
Aug 2, 2000 C3A990071 Protective Order Regarding Complainant's Rule 8210 Requests to Respondents Disciplinary Order
Jul 28, 2016 2013035817701 Protective Order Governing Personal Confidential Information Disciplinary Order
Oct 1, 2015 2013035344201 Protective Order Governing Personal Confidential Information Disciplinary Order
Jan 1, 2000 SD00004 Proposed Association of X Redacted Decision, Statutory Disqualification, Approvals
Jun 28, 2007 E102003025201 Procedural Pre-Hearing Order Disciplinary Order
Jan 2, 1998 C10970164 Pre-Hearing Scheduling Order and Rulings on Respondent's Discovery Motion Disciplinary Order
Apr 8, 2003 CAF020048 Pre-Hearing Order Directing ___________ to File a Power of Attorney Disciplinary Order
Apr 23, 2004 C9B040033 Pre-Hearing Order Disciplinary Order
Apr 4, 2002 C02010041 Pre-Hearing Order Disciplinary Order
Oct 9, 2000 C07000023 Pre-Hearing Order Disciplinary Order
Mar 22, 1998 C8A960040 Podesta & Co. & Carol P. Foley Disciplinary Decision
Nov 6, 2014 SD-2017 Piper Jaffray & Co. Statutory Disqualification, Approvals
Oct 20, 2016 SD-2071 PHX Financial, Inc. Statutory Disqualification, Approvals
Jul 25, 2007 C02040016 Philippe N. Keyes Disciplinary Decision
Dec 28, 2005 C02040016 Philippe N. Keyes Disciplinary Decision
Apr 4, 2016 20120320803-01 APPEALED: Peter J. Auzers and Shiva Naby Disciplinary Decision

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