We’ve started getting calls from former Wells Fargo employees that left the firm (resigned or were terminated) after being caught up in an internal review relating to their expenses for after-hours and weekend meals. It has been widely reported (for example here and here) that the firm has terminated several individuals for violations of policy, and are investigating many more.
This internal review has, based on information we’ve received, led to some persons having negative disclosures on their U5 about this matter. Those U5 disclosures will then lead to a Rule 8210 letter from FINRA, with the regulator seeking information about the matter from the former employee. These regulatory inquiries are serious business, and could lead to an enforcement action that makes findings of violations of industry rules and imposes sanctions on the individual, thereby damaging the person’s reputation and in some respects, their career prospects.
If you are a current Wells Fargo employee under internal review, you may consider it wise to speak with a lawyer now so that you can better prepare for different outcomes, including working to protect your U5 as best you can if you leave or are terminated. If you have already left the firm, it is certainly wise to talk with experienced legal counsel now to speak with the firm about your U5 if it has not yet been filed, and to prepare for the forthcoming FINRA examination, and then to represent you before FINRA.
We’ve got a wealth of information about the FINRA exam and enforcement processes here on our blog. And, earlier this year, attorney Joel Beck’s book, The Financial Advisor’s Guide to Regulatory Investigations, was published. The book, available on Amazon, walks the reader through the regulatory exam and enforcement processes, and helps explain what to expect, and highlights some potentially problematic areas that registered persons need to be aware of as they deal with an investigation. If you have received a Rule 8210 letter from FINRA, we’re happy to send you a free copy of the book, no strings attached, while supplies last. To request your book, go here and fill out the book request form and we’ll get it out in the mail to you.
If you’d like to speak with an experienced regulatory attorney about your situation, we invite you to contact us by telephone. We can chat for a few minutes and see if we can be of help to you.The Beck Law Firm, LLC routinely works with advisors and investment bankers across the country in FINRA regulatory matters.