As recognized by new guidance from the Financial Industry Regulatory Authority (FINRA), the departure of a registered representative often prompts customer questions about the departing representative and the continued servicing of a customer’s account. In light of the continued frequency of movement of registered representatives from, or among, member firms, FINRA issued guidance on April 5, 2019, regarding what information it expects member firms to communicate to customers upon the departure of a registered representative. Pursuant to FINRA Regulatory Notice 19-10, FINRA expects member firms to: (1) promptly and clearly communicate to affected customers how their accounts will continue to be serviced; and (2) subject to privacy and other legal requirements, provide customers with timely and complete answers, if known, to questions about a departing representative. Under this new guidance, FINRA expects member firms to implement policies and procedures that…
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