IAC Comments on FINRA Regulatory Notice Concerning Expungements

The Investor Advocacy Clinic evaluates and comments on regulatory matters and proposed rules in order to provide a voice for small retail investors.  As part of that mission, on Monday, February 5, 2018, the clinic submitted a comment letter on FINRA Regulatory Notice 17-42, a proposal making changes to the expungement process.  Expungement is the process by which broker dealers and associated persons are able to remove items, like customer complaints, from their CRD, which provides the information for BrokerCheck.

The Investor Advocacy Clinic’s comment, available in full here, expressed support for most of the suggested changes as they encouraged investor participation in the expungement process while simultaneously ensuring that only brokers actually entitled to expungement obtain that extraordinary relief.  We frequently recommend that investors consult BrokerCheck before investing, and the clinic believes that maintaining its accuracy and reliability is of the utmost importance.  We appreciate FINRA’s invitation to comment on such important matters.  Spring 2018 students Ben Dell’Orto, Esmat Hanano and Alisa Radut were the primary authors of the comment.