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AMW LAW PLLC BLOG
NEWS & ANALYSIS
Welcome to AMW Law PLLC’s legal blog, where we break down the complexities of securities laws, rules and regulations for investors and financial professionals alike.
Our posts are organized into four focused categories: Smart Investor Insights offers practical guidance on fraud risks, recovery options, and protecting your investments; Broker Compliance Center provides financial professionals with updates and strategies for staying compliant and defending against regulatory actions; Securities Law Updates highlights key developments from FINRA, the SEC, and the courts that shape the legal landscape; and Our Legal Services gives an inside look at how we help clients pursue and defend securities-related claims.
Whether you're safeguarding your portfolio or your professional standing, our goal is to keep you informed, prepared, and empowered.
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Unit Investment Trusts (UITs): What They Are, How They Work, and What Reg BI Requires When Recommendations Go Sideways
Unit Investment Trusts (UITs): What They Are, How They Work, and What Reg BI Requires When Recommendations Go Sideways Unit investment trusts occupy a strange middle ground in the investment landscape. They’re often marketed as straightforward: a defined portfolio, a defined timeline, and a defined objective—packaged into “units” that investors can buy in one transaction. For the right investor, that structure can be genuinely appealing. But the very features that make UITs e
Artur M. Wlazlo
When Fairness Demands Dismissal: What the Flesche NAC Decision Means for FINRA Respondents
When Fairness Demands Dismissal: What the Flesche NAC Decision Means for FINRA Respondents In most FINRA disciplinary cases, “fairness” is an argument respondents make and regulators acknowledge, but rarely a basis for throwing a case out altogether. That is what makes the National Adjudicatory Council’s 2025 decision in Department of Enforcement v. Paul Eric Flesche , No. 2016049565901r, 2025 FINRA DISCIP. LEXIS 18 (NAC Sep 24, 2025) so striking. After the Securities and Exc
Artur M. Wlazlo
FINRA’s Spartan Capital Private Placement Case, Part 2: Due Diligence Failures, Conflicts, and Lessons for Investors and Firms
Due Diligence Failures, Conflicts, and Lessons for Investors and Firms This article is Part 2 of a two-part series on FINRA’s enforcement case against Spartan Capital Securities. In Part 1, I explain the Atlas/StraightPath structure, how private placements work, and how Reg BI applies. You can read Part 1 here . In Part 1 of this series, I described FINRA’s complaint against Spartan Capital Securities, LLC, its CEO John Lowry, and its then–interim CCO, Kim Monchik, and walke
Artur M. Wlazlo
FINRA’s Spartan Capital Private Placement Case, Part 1: Private Placements, Reg BI, and the Atlas Funds Structure
Private Placements, Reg BI, and the Atlas Funds Structure This article is Part 1 of a two-part series on FINRA’s enforcement case against Spartan Capital Securities involving private placements and pre-IPO funds. In Part 2, I dig into FINRA’s specific due diligence and supervisory allegations and what they mean for investors and financial professionals. You can read Part 2 here . In November 2025, FINRA’s Department of Enforcement filed a disciplinary complaint against Spar
Artur M. Wlazlo
When Bad Privilege Advice and One Rule 8210 Violation Is Enough to End a Career: Lessons from FINRA’s Fetherston Case.
When Bad Privilege Advice and One Rule 8210 Violation Is Enough to End a Career: Lessons from FINRA’s Fetherston Case. The Fetherston disciplinary matter is the kind of case that makes practitioners sit up straight. After an initial Extended Hearing Panel decision, the National Adjudicatory Council (NAC) reversed the decision, sending the case back with unusually specific and pointed instructions to the Panel about how to weigh evidence, how to apply the preponderance standa
Artur M. Wlazlo
FINRA Rule 8210: FINRA’s New Reminder that Jurisdiction Follows You - Wherever You Are.
FINRA Rule 8210: FINRA’s New Reminder that Jurisdiction Follows You - Wherever You Are. On September 25, 2025, FINRA issued Regulatory Notice 25-11, titled “FINRA Reminds Members and Associated Persons, Wherever Located, of Their Obligation to Comply With Rule 8210.” At first glance, this notice may appear to restate familiar obligations. But for professionals and firms with any international dimension, registered representatives working abroad, dual-licensed entities, or f
Artur M. Wlazlo
“Willful” Violations, Statutory Disqualification, and the Path Back: What Financial Professionals Need to Know.
“Willful” Violations, Statutory Disqualification, and the Path Back: What Financial Professionals Need to Know. In securities regulation,...
Artur M. Wlazlo
FINRA Defense Counsel for Financial Professionals, Compliance Officers & Brokerage Firms
FINRA Defense Counsel for Financial Professionals, Compliance Officers & Brokerage Firms In today’s regulatory environment, financial professionals operate under intense scrutiny. A single misstep, or even an unfounded allegation, can jeopardize your registration, reputation, and career. At AMW Law PLLC, we provide focused, experienced defense in matters involving FINRA investigations, disciplinary proceedings, customer complaints, and arbitration claims. Whether you are a re
Artur M. Wlazlo
Supervision That Works: Practical Lessons from a Former FINRA Enforcement Attorney
Supervision That Works: Practical Lessons from a Former FINRA Enforcement Attorney If you work as a financial or compliance professional...
Artur M. Wlazlo
Avoiding Unfair FINRA Proceedings: Defending Against FINRA Charges in Delayed Regulatory Proceedings
Avoiding Unfair FINRA Proceedings: Defending Against FINRA Charges in Delayed Regulatory Proceedings Although FINRA disciplinary actions...
Artur M. Wlazlo
FINRA Defense Attorney and Investment Lawyer for Financial Professionals: Trusted Counsel in a Complex Industry
FINRA Defense Attorney and Investment Lawyer for Financial Professionals: Trusted Counsel in a Complex Industry The investment industry has never been more complex or more scrutinized. Financial professionals are expected to deliver sound advice, navigate shifting regulatory standards, and defend their conduct under the threat of arbitration , compliance action, or reputational harm. When legal issues arise, having an experienced and strategic FINRA defense attorney and inves
Artur M. Wlazlo
When Annuity Exchanges Go Wrong: FINRA Enforcement Action Highlights Risks of Registered Index-Linked Annuities (RILAs) Recommendations
When Annuity Exchanges Go Wrong: FINRA Enforcement Action Highlights Risks of Registered Index-Linked Annuities (RILAs) Recommendations...
Artur M. Wlazlo
FINRA Rule 8210 Inquiries and Regulatory Investigations: What to Know and Other Insights from a FINRA Regulatory Defense Attorney.
FINRA Rule 8210 Inquiries and Regulatory Investigations: What to Know and Other Insights from a FINRA Regulatory Defense Attorney. FINRA Rule 8210 is one of the most powerful tools in the arsenal of the Financial Industry Regulatory Authority (FINRA) and plays a central role in the organization’s ability to carry out its regulatory mission. This rule grants FINRA the authority to request documents, data, and testimony from member firms, associated persons, and other relevant
Artur M. Wlazlo
FINRA Rule 2010’s Broad Business-Related Scope Affirmed: The Iannazzo Case’s Implications for Personal Misconduct and Professional Consequences.
FINRA Rule 2010’s Broad Business-Related Scope Affirmed: The Iannazzo Case’s Implications for Personal Misconduct and Professional Consequences. Earlier this year, I wrote about the extraordinary flexibility of FINRA Rule 2010 in my article The Expansive Reach of FINRA Rule 2010: Ethical Standards Beyond Securities Transactions . As discussed there, Rule 2010 operates both as a companion to other FINRA rules and as an independent ethical standard capable of reaching misconduc
Artur M. Wlazlo
The Expansive Reach of FINRA Rule 2010: Ethical Standards Beyond Securities Transactions
The Expansive Reach of FINRA Rule 2010: Ethical Standards Beyond Securities Transactions In the highly regulated world of financial services, much attention is paid to the detailed, technical requirements imposed by FINRA’s rulebook. Yet, beneath these specific provisions lies one of the most powerful and flexible rules in the entire securities regulatory framework: FINRA Rule 2010. Though its language is sparse, its reach is expansive, and its enforcement has proven to be a
Artur M. Wlazlo
Understanding FINRA Rules on Outside Business Activities and Private Securities Transactions
FINRA Rules on Outside Business Activities and Private Securities Transactions: What You Need to Know. Navigating FINRA’s rules on Outside Business Activities (OBAs) and Private Securities Transactions (PSTs) can be confusing, as both involve financial professionals engaging in activities outside their primary brokerage firms. However, these two categories have distinct regulatory implications. This blog will clarify the differences, the applicable FINRA rules, and the compli
Artur M. Wlazlo
Understanding On-the-Record Interviews and Requests for Documents Under FINRA Rule 8210.
Understanding On-the-Record Interviews and Requests for Documents Under FINRA Rule 8210. The Financial Industry Regulatory Authority (FINRA) plays a vital role in overseeing broker-dealers and registered representatives to ensure compliance with securities laws and regulations. One of the tools FINRA uses to carry out its regulatory functions is FINRA Rule 8210, which grants FINRA the authority to request information, documents, and testimony from member firms and associated
Artur M. Wlazlo
Understanding FINRA Disciplinary Hearings: An Overview.
Understanding FINRA Disciplinary Hearings: An Overview. The Financial Industry Regulatory Authority (FINRA) plays a critical role in regulating the securities industry. Part of its mandate involves conducting disciplinary hearings to address violations of securities laws and FINRA rules. The process of a disciplinary hearing encompasses several stages, including investigation, on-the-record (OTR) interviews, hearings, and potential appeals to the National Adjudicatory Council
Artur M. Wlazlo
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