FINRA Code of Procedure

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What this video covers

  • How the Department of Enforcement receives authorization from the Office of Disciplinary Affairs before filing a complaint with the Office of Hearing Officers (OHO)
  • What a default decision is and why failing to answer a complaint or appear at a pre-hearing conference results in deemed admissions and imposed sanctions without a full hearing
  • The composition of a standard Hearing Panel (one Hearing Officer plus two industry panelists) and why decisions are by majority vote, not the Hearing Officer's veto
  • The 60-day maximum for the Hearing Officer to draft and issue the written decision after the Chief Hearing Officer sets a preparation date
  • How the 25-day appeal window to the National Adjudicatory Council (NAC) starts from service of the decision, not the date written on the document
  • Why appellate risk matters: the NAC can affirm, modify, reverse, increase, or decrease sanctions, not merely uphold or reduce them
  • Why SEC review is a record review based on the OHO evidentiary record, not a de novo hearing permitting new evidence

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