Apr. 30, 2020
SECURITIES AND EXCHANGE COMMISSION [Release No. 34–88600; File No. SR–FINRA– 2020–011] Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of a Proposed Rule Change To Address Brokers With a Significant History of Misconduct April 8, 2020. My concern would be to ensure due process, both appearance and actual. Process participants need to have, and know they have, all due process rights in place. This ensures a full development of the record and helps cut off messy arguments in appellate processes. I would add verbiage regarding due process presence and preservation to notice/training materials. Just my thoughts … I can provide case cites if you think it would be helpful. Many thanks for all you do. Best, Prof. Lisa Miller, Esq. FINRA Public Arbitrator/Chair