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FINRA ordered an investment bank to pay more than $10 million in restitution for suitability violations relating to mutual fund transactions. FINRA found that from January 2010 through June 2015, the bank's supervisory systems were not sufficient to prevent unsuitable switching. In particular, the firm incorrectly defined a mutual switch in its supervisory procedures to require three separate transactions within a certain time frame. Based on this incorrect definition, the bank (i) failed to act on thousands of automated alerts for potentially unsuitable transactions, (ii) excluded