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Textbook
Introduction
1. Common stock
2. Preferred stock
3. Debt securities
4. Corporate debt
5. Municipal debt
6. US government debt
7. Investment companies
8. Insurance products
9. The primary market
10. The secondary market
11. Brokerage accounts
12. Retirement & education plans
13. Rules & ethics
13.1 The regulators
13.2 Public communications
13.3 Social media
13.4 Regulation BI
13.5 Registered representative rules
13.6 Regulation S-P
13.7 Protecting vulnerable investors
13.8 Restitution & penalties
13.9 Recordkeeping requirements
14. Suitability
Wrapping up
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13.1 The regulators
Achievable Series 6
13. Rules & ethics

The regulators

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Finance affects everyday decisions - travel, housing, raising a family, and retirement all depend on having (and managing) money. That’s why financial professionals work in a field where trust matters. A common saying captures the idea:

“If you want to keep someone happy, don’t mess with their food or money.”

In many roles, financial professionals handle or influence significant amounts of money. That comes with real responsibility. To operate legally and ethically, you need to understand the rules that govern the industry. You’ll also sometimes need to think like a criminal - understanding the incentives behind prohibited behavior helps you recognize, stop, and report it.

Several regulators enforce financial rules and regulations. You were introduced to them for the SIE exam, and they’ve come up throughout this program. This review focuses on:

  • The SEC
  • FINRA
  • The MSRB
  • NASAA

The SEC

As we learned in the primary market chapter, the Securities and Exchange Commission (SEC) is the primary securities regulator in the financial markets. The SEC is an independent agency of the US Government. It was created by the Securities Exchange Act of 1934, and it also enforces rules and regulations under the Securities Act of 1933 and the Investment Company Act of 1940. The SEC has three primary goals:

  • Protect investors
  • Maintain fair, orderly, and efficient markets
  • Facilitate capital formation

Protecting investors is the SEC’s core purpose. In most situations where the SEC appears in this material, the goal is to reduce fraud and unethical behavior. The SEC is generally most focused on protecting smaller, retail investors. Institutions typically have substantial legal and financial resources, which makes them less likely to be victimized by bad actors. This is why you’ll sometimes see rules that don’t apply (or apply differently) when institutions are involved - Regulation D is a good example.

Maintaining fair, orderly, and efficient markets is about market confidence. This goal is closely tied to the secondary market and the Securities Exchange Act of 1934, which we covered in the secondary markets chapter.

Facilitating capital formation means supporting a system where issuers can raise capital (money) by selling securities. Many rules make the process of registering securities difficult and costly, so the SEC aims to balance investor protection with the ability to raise funds efficiently. Non-exempt issuers selling significant amounts of securities to the public often must complete formal registration, but many exemptions exist for smaller offerings and securities sold to private audiences.

FINRA

The Financial Industry Regulatory Authority (FINRA) is the primary regulator you’ll deal with in day-to-day industry life. FINRA is a private organization, but it’s also a self-regulatory organization (SRO) that has been approved by the SEC to exercise regulatory authority.

Sidenote
Designated examining authorities (DEAs)

The exam may mention a DEA. This does not refer to the Drug Enforcement Administration. Here, DEA means designated examining authority, which is another term used for an SRO. So, FINRA is both an SRO and a DEA.

Although the full structure is more complex, a helpful way to think about it is:

  • The SEC oversees the broader securities markets and major federal securities laws.
  • FINRA focuses on regulating member firms and their representatives.

FINRA enforces its own rules and also enforces the rules of other SROs (such as the MSRB).

FINRA also writes and administers exams like the SIE and Series 6. Passing these exams is part of becoming a registered representative who can work with customers of securities firms. In most cases, you must be registered with FINRA to operate legally in the industry.

To register with FINRA, you’ll complete and file Form U-4, the Uniform Application for Securities Industry Registration or Transfer. Your firm will usually guide you through the process. The form can feel personal because it requires detailed background information, including:

  • 5-year residential history
  • 10-year employment history
  • Outside business activities
  • Financial disclosures (bankruptcies and compromises with creditors)
  • Any felony history (including charges)
  • Any securities-related misdemeanor history (including charges)
  • Items subject to statutory disqualification
Sidenote
Securities-related misdemeanors

Form U-4 requires disclosure of any history of securities-related misdemeanors. A common question is what counts as “securities-related.” This is a direct quote from Form U-4:

[A securities-related misdemeanor is one] involving: investments or an investment-related business or any fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses

Most test questions will describe these generally as “securities-related.” The quote shows the types of conduct included.

Some past events can prevent someone from working in the securities industry. While Form U-4 requires disclosure of criminal-related events (even without a conviction or guilty plea), only convictions or guilty pleas typically create an automatic barrier to registration. These are called statutory disqualifications and usually involve criminal activity or serious rule violations. The following items can lead to a U-4 being denied:

  • Conviction of any felony in the last 10 years
  • Conviction of a securities-related misdemeanor in the last 10 years
  • Suspension or revocation of registration from another securities regulator (e.g. SEC) or SRO (e.g. MSRB)
  • Proof of false statements made to securities regulators or SROs

Firms often ask early in the hiring process about criminal convictions (and sometimes arrests) because a felony or securities-related misdemeanor may prevent registration. In some cases, a firm can request an exception and attempt to register someone despite a disqualifying event. For example, a broker-dealer might argue that a felony conviction from eight years ago should not prevent registration. This request is an Eligibility Proceeding. The firm files the request with FINRA, FINRA forwards it to the SEC, and the SEC makes the final decision.

To confirm the information on Form U-4, firms conduct background investigations on new hires. FINRA rules require firms to investigate the good character, business reputation, qualifications, and experience of each representative they plan to register. Fingerprints are also collected and sent to the FBI. This helps confirm identity and check for outstanding criminal issues.

After the background check, the employee signs the U-4. The signature confirms the information is accurate and also accepts an arbitration agreement embedded in the form. As covered earlier, this generally prevents representatives from suing their employer unless allegations of harassment or discrimination exist.

Once signed, the firm submits the U-4 to FINRA’s Central Registration Depository (CRD). The CRD is a database containing information on registered representatives across the industry. Customers can view certain information through FINRA’s BrokerCheck (you may already appear there). The CRD also contains information on FINRA member firms, meaning firms registered with FINRA - broker-dealers are a common example.

Form U-4 must be updated when information changes. Some updates are routine (such as a name or address change). Others involve events that can affect employment or registration status. If an event involving a statutory disqualification occurs after registration, the U-4 must be updated within 10 days of the event. For example, a registered representative convicted of a securities-related misdemeanor would need to update the U-4. In many cases, such events lead to revocation of registration and termination.

When a representative’s employment ends, the firm must file a U-5 with FINRA within 30 days. If FINRA removes registration due to a rule violation, the registration is revoked. Not every departure is negative, though. If a representative quits or retires, the registration is canceled. Revocation is punitive (a punishment); cancellation is not. U-5 information is also available on BrokerCheck.

After a registration is revoked or canceled, FINRA maintains regulatory authority for 2 years. For example, if someone quits and their registration is canceled, and then a legitimate customer complaint alleging fraud is filed afterward, FINRA can still revoke the person’s license. That revocation can prevent the person from re-entering the industry later.

Form U-6 is filed when a representative or firm is subject to disciplinary action or when a reportable event occurs. Reportable events include criminal convictions and financial disclosures (bankruptcy and compromises with creditors). Arbitration dispute outcomes are also reported on this form. Like the U-4 and U-5, U-6 information is available on BrokerCheck.

MSRB

The Municipal Securities Rulemaking Board (MSRB) is an SRO that writes rules for the municipal securities markets and their participants. Its rules do not apply to municipal issuers. The MSRB writes rules but does not enforce them. The following organizations enforce MSRB rules:

Enforces MSRB rules for securities firms

  • Securities and Exchange Commission (SEC)
  • Financial Industry Regulatory Authority (FINRA)

Enforces MSRB rules for banks

  • The Federal Reserve Board
  • Office of Comptroller of the Currency
  • Federal Deposit Insurance Corporation (FDIC)

NASAA

The North American Securities Administrators Association (NASAA) is a group of state securities administrators. Each state has its own administrator - an office responsible for enforcing rules under the Uniform Securities Act. You can think of NASAA as the state-level counterpart to federal securities regulation. You won’t need much NASAA detail for the Series 6, but it becomes central on the Series 63, 65, and 66. NASAA writes and administers each of those exams.

Key points

Securities and Exchange Commission (SEC)

  • Prominent securities industry regulator
  • Regulates the primary and secondary markets
  • Enforces:
    • Securities Act of 1933
    • Securities Exchange Act of 1934
    • Investment Company Act of 1940
  • Main goals:
    • Protect investors
    • Maintain fair, orderly, and efficient markets
    • Facilitate capital formation

Financial Industry Regulatory Authority (FINRA)

  • Regulates financial industry and its participants

U-4

  • Registration form for persons in finance
  • Filled out and filed when joining a firm
  • Requires extensive background information
  • Must be updated if information changes
  • Arbitration agreement is embedded

Statutory disqualifications

  • Events that may prevent or revoke registration
  • Most commonly cited:
    • Any felony conviction in the past 10 years
    • Securities-related misdemeanor in the past 10 years
    • Punishment from other regulators

U-5

  • Removes registration status
  • Filled out and filed when leaving a firm

U-6

  • Reports the following:
    • Disciplinary actions
    • Reportable events
    • Arbitration results

Municipal Securities Rulemaking Board (MSRB)

  • Self-regulatory organization governing the municipal markets
  • Writes municipal regulations, does not enforce
  • Enforces MSRB rules (securities firms):
    • SEC
    • FINRA
  • Enforces MSRB rules (banks):
    • The Federal Reserve Board
    • Office of Comptroller of the Currency
    • Federal Deposit Insurance Corporation (FDIC)

North American Securities Administrators Association (NASAA)

  • Regulates financial industry at the state-level
  • Enforces provisions of the Uniform Securities Act

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