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Patrick Chylinski, CVA, CFE
515 South Flower Street 41st Floor
Los Angeles CA 90071-2201
USA
phone: 213-330-4605
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RSM US, LLP is the 5th largest Accounting and Consulting Firm in the country, with over 85 offices across the United States. Our litigation consulting and financial forensics practice focuses on assisting counsel and clients in the areas of business and commercial litigation matters, forensic and fraud investigations, contract compliance matters, and royalty inspections.

Our professionals have extensive experience assessing and quantifying damages in a variety of matters including contract disputes, post-closing and post-acquisition disputes, breach of fiduciary duty matters, real estate disputes, fee disputes, partnership disputes, as well as conducting analysis in forensic and fraud matters.

Industry experience includes, among others, technology, manufacturing, hospitality, government and public sector, banking, consumer products, real estate, financial services, and entertainment. Our team of consultants has qualifications, certifications, and educational experience that include Certified Public Account (CPA), Master Analyst in Financial Forensics (MAFF), Certified Fraud Examiner (CFE), Certified in Financial Forensics (CFF), Certified Valuation Analyst (CVA), MBA, and JD.

Our professionals have experience testifying at deposition, arbitration, and trial and have experience working in the following types of matters:
  • Economic Damage Analysis
  • Fee Disputes
  • Billing Disputes
  • Breach of Contract Matters
  • Post-acquisition Disputes
  • Earn-out Disputes
  • Fraud Investigations
  • Forensic Investigations
  • Breach of Fiduciary Duty Matters
  • Business Interruption Matters
  • Construction Claims
  • Covenant Not To Compete Matters
  • Business Valuations
  • Contract Compliance / Royalty Investigations
  • Health Care Litigation Matters
  • Insurance Claims & Coverage Disputes
  • Intellectual Property Related Matters
  • Marital Dissolution Matters
  • Purchase and Sale Disputes
  • Securities Litigation Matters
  • Patrick Chylinski Economic Damages Expert PhotoPatrick Chylinski, MAFF, CVA, CFE is a principal and the West Region Practice Leader for RSM’s Litigation Consulting and Financial Forensics practice. He has extensive experience managing and directing engagements relating to complex commercial litigation, business disputes, investigations of fraud and financial misconduct, and business valuations. He has been designated as an expert in numerous cases, and has testified as an expert in litigation matters relating to contract and fee disputes. Mr. Chylinski has experience serving clients across various industries including healthcare, financial services, real estate, construction, insurance, gaming, entertainment, and technology.

    Past experience includes roles as a Director of the Litigation Consulting and Forensic Accounting Services practice group for a top-25 national accounting and consulting firm, as well as a leadership position at a top regional firm. Earlier in his career, Patrick worked in the Financial Advisory Services group at Deloitte & Touche, focusing on dispute consulting.

    In addition to his work experience in professional services, Patrick has extensive industry experience, having worked as a Vice President of Financial Planning and Analysis for what was one of the largest mortgage banking and financial services firms in the country. Patrick also worked in commercial real estate, performing financial analysis and mergers and acquisition due diligence at a commercial real estate investment firm. He also has experience in the securities industry, at one time holding NASD Series 7 and 63 licenses.

    Litigation and Dispute Services:
    • Contract Disputes
    • Fee Disputes
    • Damage Analysis
    • Lost Profit Analysis
    • Partnerships and Real Estate Disputes
    Forensic and Investigative Services:
    • Licensing and Royalty Disputes
    • Purchase Price / Earn-out Disputes
    • Forensic Analysis
    • Fraud Investigations
    • Contract Compliance
    8/20/2014 · Forgery & Fraud
    When many people think about fraud, their thoughts usually turn to banks, investment firms and large businesses. But don't be fooled. Not-for-profit organizations – including many charities, colleges, religious entities and trade groups – are often easy targets for sophisticated fraud schemes.

    Business acquisitions and dispositions are often highly complex transactions which can possess an increased potential for disagreements-disagreements that can eventually lead to contentious and costly litigation. Various types of disputes can arise from the purchase or sale of a business, and these post-closing or postacquisition disputes can delay or even derail what may otherwise appear as obvious "win-win" transactions.

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    Gontran de Quillacq
    Securities Consultant / Quantitative Portfolio Manager
    FINRA Arbitration
    NY / NJ
    USA
    phone: 732-533-9066
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    Gontran de Quillacq has over 20 years of Securities experience specializing in Portfolio Management, Equity Derivatives Trading, Proprietary Trading and Investment Research. He has worked with top-tier banks and hedge funds in both London and New York.

    Background Experience - A proprietary and derivatives trader, Mr. de Quillacq traded derivatives, from vanillas to exotics. As a portfolio manager, he researched and managed investment strategies, delivered both in hedge fund and in structured note formats. He actually initiated the distribution of investment strategies with derivatives, an activity now called 'portable alpha' and 'smart beta'. For five years, Mr. de Quillacq then ran due diligence on investments strategies and selected senior investment personnel for some of the world’s most famous and most demanding hedge funds and asset managers - portfolio managers, analysts, quants, CIOs, CROS. In 2017, he co-founded a quantitative fund deploying the latest machine learning techniques in global long/short equities.

    Litigation Support - Mr. de Quillacq's investment experience and cross-sectional review of other professionals give him unique experience on what can be done, what should be done, what should not be done, and the grey areas in-between. During a personal case against HSBC, his legal team was so impressed by his wide and thorough knowledge in finance, his capacity to explain complicated ideas in simple terms, and his strong performance on the stand, that they strongly recommended he expand his litigation support services.

    Mr. de Quillacq's services are available to attorneys representing plaintiff and defendant and include written reports, deposition, arbitration, mediation, and trial testimony as needed.

    Areas of Expertise:
    • Investments and Trading: Securities and derivatives (stock options, swaps, exotics...), structured products, complex financial instruments, benchmarks manipulation (Libor, FX, indices), liquidity management, statistical arbitrage and algorithmic trading, portfolio construction and risks, management fees, broker dealers, hedge funds
    • Recruitment and Employment: Front-office personnel, portfolio managers, traders, quants, analysts, broker-dealers, compensation, due diligence, U5
    • Supported Practice Areas: Financial fraud & litigation, commodities & securities manipulation, white-collar crime, broker-dealers, hedge funds, investigations, enforcement, whistleblowing, ADR, FINRA arbitrations
    Education / Training:
    • HEC Paris, MBA Finance, 1995
    • US Berkeley, visiting scholar, differential algebra, 1993
    • Ecole Superieure d'Electricite, doctoral degree (DEA), 1993
    • Stanford Research Institute, international fellow, atomic physics, 1992
    • Ecole Normale Superieure de Lyon, MS theoretical physics, 1992
    • Ecole d'Application du Train, lieutenant, 1990
    • Lycee Faidherbe, classes preparatoires, 1989
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    W. Timothy Finn
    Managing Partner
    483 Emerald Hill Road
    Russell Springs KY 42642
    USA
    phone: 270-866-2566
    fax: 270-866-4624
    Financial Management Consulting Group is an affiliation of well-experienced consultants serving banking interests throughout the country. Our years of experience, as bankers, as bank consultants, and as regulators provide valuable insight into case matters.

    We can assist both from the industry perspective and from the regulatory perspective, offering a comprehensive assessment and well supported opinion. We have qualified as experts in numerous State and Federal jurisdictions, and on numerous banking related matters. We are dedicated to providing clients with quality, results-oriented service.
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    Michael K. Smith, NFA, FINRA
    Bozeman MT USA
    phone: 630-531-1000
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    Michael K. Smith, NFA, FINRA is a highly experienced Financial Services Executive and Finance Professional with over 40 years dedicated to high-end client representation and large-scale regional management.

    As Managing Director and as Regional Manager since 1997, Mr. Smith was responsible for all aspects of the securities and banking activities within the Midwest region for three major firms: Lehman Brothers, Barclays Wealth and Citi Private Bank. He was responsible for supervising more than 50 registered representatives.

    From 1982 to 1997, Mr. Smith was a dedicated Top Producer accustomed to results-based rewards for services provided to Morgan Stanley’s ultra high net worth clients (UHNW). He specialized in developing and executing solutions to meet complex financial objectives. This period was highlighted by providing substantial agency, principal and fiduciary related transactional and investment management business for top-tier clients with $25MM - $10B net worth.

    Mr. Smith offers substantive experience and expertise in the following:
    • Options
    • Futures
    • Commodities
    • Common Stock, Preferred Stock
    • Municipal Bonds
    • Corporate Bonds
  • Hedge Funds
  • Margin & Lending
  • Derivative Securities
  • Limited Partnerships
  • Mutual Funds & ETF's
  • Discretionary Managed Assets
  • Litigation Support - Michael Smith has distilled his 40 year career in Securities and Banking into a focused expert practice. His nationwide services are requested when a client is contemplating filing an arbitration claim or after an arbitration claim or suit has been filed. He acts as an expert witness for plaintiffs or defendants involved in the following claims:
    • Misrepresentation
    • Unsuitable Trading
    • Breach of Fiduciary Duties
    • Failure to Supervise
    • Omission of Facts
    • Negligence
    • Churning
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    Kelly Hickel
    Co-Founder and Main Contact
    950 3rd. Avenue
    17th Floor
    New York NY 10022
    USA
    phone: 212-486-3600
    fax: 303-484-5374
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    Expert Witness Consulting Services, LLC (EWCS) provides a range of services to law firms, litigation trustees and others engaged in expert witness and related activities. We provide up-front assessment of cases, drafting assistance in writing the economic core of complaints; other consulting expert work; and testifying expert witness reports and testimony.

    As an affiliate of Gordian Group (one of the leading national restructuring investment banking firms), EWCS can tap Gordian's vast experience in litigation assignments, particularly relating to matters involving solvency, valuation, fairness and Board of Directors responsibilities. In addition, EWCS has built a nationwide cadre of other independent experts so that we can assist law firms and mediators in finding the right expert for each case. EWCS connects vetted and specialized expert witness professionals to law firms across the nation. With its incremental, litigation-experienced human resources and national recognition within the legal community, EWCS’ mission is to work diligently with client law firms and mediators to provide exceptional work product in an efficient manner, starting with finding the right expert for each case.

    As Consultants, the professionals at EWCS are able to provide clients and Boards of Directors with advice and guidance in structuring transactions appropriately, and in delivering financial opinions in connection with the same. They can reconstruct financial data through forensic analysis in order to explain how financial markets or decision makers may have made decisions.

    When it comes to evaluating the performance of boards, management teams, and financial institutions, the experts at EWCS are well-positioned to have a credible point of view, given their experience in cleaning up the aftermath of corporate disasters and fraud up close.

    The EWCS professionals have substantial experience in most industries, including but not limited to aerospace and defense; consumer goods; electronic technology; finance and insurance; food and beverages; heavy industry and manufacturing; life sciences; metals & mining; oil & gas and energy; real estate and hospitality; and retail and apparel. Their experts have done transactions within these segments, and use their “real world” experience in approaching projects.

    Areas of Expertise:
    • Financial Services
    • Economics
    • Restructuring
    • Bankruptcy
    • International Business (particularly in Asia)
    • Fiduciary Duties
    • Private Placements
    • Damages
  • Equity Compensation
  • Market Assessments
  • Business Valuations
  • Manufacturing
  • Pharmaceuticals
  • Technology
  • Intellectual Property / Patents
  • Real Estate Market Feasibility
  • Kelly Hickel Financial Restructuring Expert PhotoKelly T. Hickel, Co-founder at EWCS, is a Financial and Business Advisor who has served as a senior executive for over 30 years. Mr. Hickel has many years of experience in the technology industry and with turnarounds of troubled companies. Throughout his career, he has arranged numerous private and public company financings and financial restructurings and has raised and/or returned over a $1 billion to investors and lenders.

    Mr. Hickel served as Turn-around President to Miniscribe Corp., a troubled Fortune 500, $600 million annual revenue disk drive manufacturer, and President of the Maxwell Technology Information Systems Group from 1993 until 1997, during which, Maxwell was the 9th best performing stock on NASDAQ and the #1 performing stock in California in 1996.

    As Chairman and Chief Restructuring Office of The Tyree Company in Farmingdale, New York, Mr. Hickel was responsible for running the largest oil downstream services company in the northeast. With all of his experience, he then founded and managed emerging Pharmaceutical companies, taking a product through FDA approval for a supplement through distribution in over 2000 retail pharmacy outlets.

    Jim Timmins Business Valuation Expert PhotoJim Timmins, ASA BV/IA, MAFF, CEP, is the Managing Director and heads the valuation, litigation, and advisory services practices at Teknos. He has worked in Silicon Valley for more than 35 years, as a Valuation expert, a Venture Capitalist, and an Investment Banker.

    Mr. Timmins has overseen 1,000s of valuations, fairness opinions, and solvency opinions in connection with financial reporting, tax compliance, merger and acquisition transactions, financings, spin-offs, and recapitalizations, and litigation. He has also participated in numerous merger and acquisition transactions, private placements, and public offerings during his career.

    Prior to forming Teknos, Mr. Timmins was a Managing Director at Pagemill Partners, where he created and managed the valuation practice. Before that he was the Managing Director of the Silicon Valley office of NIF Ventures (the venture capital arm of Daiwa Securities SMBC of Japan), and a General Partner of Glenwood Ventures and Glenwood Capital. Earlier in his career, he held positions in investment banking at Hambrecht & Quist and Salomon Brothers.

    Mr. Timmins has served as an expert witness for more than 60 cases involving valuation, fiduciary duty, and venture capital practice. He has been retained as an expert by both plaintiffs and defendants.

    Paul Black Real Estate Expert PhotoPaul S. Black, President of Paul S. Black & Assoc., Inc. has more than 35 years of experience as a Real Estate Market Feasibility Analyst, including multiple types of residential, office, retail, industrial and mixed-use properties.

    Mr. Black has been employed by local and international accounting firms in their real estate consulting groups as well as local and regional consulting companies.

    For 20 years, Mr. Black has served as a lecturer/adjunct professor teaching Real Estate Principles and Practices as well as Real Estate Market Analysis at the graduate (MBA) and undergraduate levels.

    Areas of Expertise: Economic Damages, Construction Defects / Delay Damages, Lost Revenue / Profits, Unjust Enrichment, Due Diligence, Commission Disputes, Procuring Cause, Real Estate Brokerage, Broker/Realtor Standard of Care, Code of Ethics – National Association of Realtors (NAR), Real Estate Disputes, Fraud / Misrepresentation, Insurance Defense, Eminent Domain, Market Feasibility / Evaluation.
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    Donald M. May, PhD, (Financial Economics), CPA
    Managing Partner
    4 Lynwood Ct.
    Cortlandt Manor NY 10567
    USA
    phone: 212-390-0595
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    DMA Economics, LLC is a world class provider of Valuation Analyses in high-stakes litigation. Their clients include billion-dollar investment funds under SEC investigation as well multi-national firms involved in intellectual property disputes, consumers in product mislabeling cases, and small to mid-sized businesses involved in complex commercial litigation.

    DMA Economics has performed valuations for cases involving Theft of Trade Secrets, Securities Fraud, Product Mislabeling and Consumer Fraud, and Lost Profits and Enterprise Value to name a few.

    DMA Economics also has extensive experience in the valuation of business interests for non-litigation matters. These include but are not limited to valuations of non-public business interests, for acquisition and regulatory purposes.

    Donald May Business Damages Expert PhotoDonald M. May PhD, CPA, Managing Partner at DMA Economics, LLC, possesses over 30 years of Valuation and Economic Damages experience. He implements a broad range of damage analyses and valuations for clients including billion dollar investment funds under SEC investigation as well as smaller businesses concerned with the impact of potential litigation and strategies to reduce potential liability.

    Background Experience - Prior to founding DMA Economics LLC, Dr. May was Managing Director at Berkley Research Group and the Principal in charge of valuation and litigation support services for a regional accounting firm, a Managing Director for PricewaterhouseCoopers, and a professor at the Massachusetts Institute of Technology - Sloan School of Management. He has performed over 200 valuations of closely held businesses across numerous industries for financial reporting and estate planning.

    Dr. May has been published in several distinguished academic and practitioner journals such as The Journal of Finance, The Quarterly Review of Economics and Finance, Hedge Fund Law Review, and is currently an editorial board member of The Journal of Business Valuation and Economic Loss Analysis.

    View Donald May's Expert Witness Profile.
    12/14/2017 · Economics
    This article finds evidence consistent with the hypothesis that managers consider personal risk when making decisions that affect firm risk. I find that Chief Executive Officers (CEOs) with more personal wealth vested in firm equity tend to diversify. CEOs who are specialists at the existing technology tend to buy similar technologies. When specialists have many years vested, they tend to diversify, however. Poor performance in the existing lines of business is associated with movements into new lines of business.

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    Charles Porten, CFA
    CFA, President
    9 Little Fox Lane
    Weston CT 06883
    USA
    phone: 203-454-4615
    fax: 203-227-2763
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    Charles Porten, CFA, is a Registered Investment Advisor, Chartered Financial Analyst, and investment expert with more than 30 years of experience in portfolio management of trust and advisory accounts, brokerage accounts, hedge funds and mutual funds, due diligence procedures, and compliance issues. His clients include attorneys, individuals, banks, investment advisors, broker-dealers, corporations, and the SEC.

    Background Experience - Mr. Porten has an extensive background within broker-dealer, investment advisor and bank trust environments and overseeing organizations staffed by as many as 100 personnel in managing asset bases as high as $20 billion. He has been an analyst, research director, portfolio manager, chief investment officer, business manager, and registered representative at four leading financial institutions. He has also been a guest lecturer at Harvard Law School and serves as a FINRA arbitrator.

    Litigation Support - Mr. Porten has testified over 75 times in court, depositions and arbitrations. He has been qualified to testify as an expert witness for both plaintiff and defendant on matters including:
    • Fiduciary Duty
    • Hedge Funds
    • Mutual Funds
    • Trusts and Estates
    • Variable Annuities
    • Investment Advisor
    • Brokerage Accounts
    • Portfolio Management
    • Due Diligence
    • Supervision
  • Standards of Care
  • SEC
  • Exchange Funds
  • ETF's
  • ERISA
  • IRA's
  • Securities Fraud
  • Acquisions
  • Suitability
  • Compliance Issues
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    Wayne Citron
    Insurance Consultant
    6 Carter Dr.
    Marlboro NJ 07746
    USA
    phone: 800-248-7661 or 732-972-9500
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    CMC Advisors Inc. (CMC) provides expert Insurance Consulting and offers clients the upper hand in managing their assets and liabilities. They assist clients in managing investment portfolios by helping to determine if current Financial Retirement plans such as IRA, Roth IRA, Rollover IRA, 401(K), Keogh Plans, Pensions and Profit Sharing Plans are meeting retirement goals.

    Consulting Areas:
    • Annuities
    • Life Insurance
    • Term Insurance
    • Single Premium Variable Insurance
  • Retirement
  • Disability
  • Insurance Consultant
  • Expert Witness Services
  • Wayne Citron has 45 years of experience as an expert in Forensic Reconstruction of Insurance Transactions. He is an insurance expert and consultant.

    Mr. Citron established the Citron Agency and CMC Advisors Inc. in 1972, where his duties included executive and managerial responsibilities, sales, service, compliance with all insurance matters as well as securities laws and regulations. Both firms are leaders in life, health, disability and property and casualty insurance.

    Mr. Citron has served as an instructor for Prudential Insurance Company Brooklyn Agency (1973) educating personnel in general insurance matters, underwriting, and insurance law. He has worked with companies including Prudential Insurance Company, United States Life Insurance Company, North American Company for Life and Health Insurance, American General Life Insurance Company, William Penn Life Insurance Company, American Life Insurance Company, Chubb Insurance Company, Travelers Insurance Company, Mass Mutual Insurance Company, John Hancock Insurance Company, and American International Group (AIG), among other.

    Mr. Citron recently volunteered for Ocean County Long Term Recovery Group (OCLTRG) to reopen Super Storm Sandy flood claims and examine National Flood Insurance Policies, as well as deal with FEMA in these matters (2015 & 2016).

    View Wayne Citron's Expert Witness Profile.
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    John T. Foster, CAMS
    President & CEO
    NJ USA
    phone: 609-707-1071
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    Bedford and Main Financial Consulting provides consulting services catering to the broker-dealer community. This includes Introducing Brokers, Self-clearing Brokers, Correspondent Clearing firms, Independent or W-2 based advisor models, Secondary Clearing or “Piggyback” firms and often start-up broker-dealers and those looking for an acquisition partner. Yes, we will assist other related financial services clients when it is a good fit, but we stay true to our core competencies.

    Our experience is both deeply rooted yet freshly relevant. With over 35 years of hands-on senior experience, our management has been actively building, growing and restructuring broker-dealers. While based in the metropolitan Philadelphia area, Bedford and Main's client base is global.

    Our “bread and butter” work and expertise focuses on conversions and project management. We have helped firms merge together, switch clearing firms, implemented new processing platforms and established trade execution, clearing, and custody relationships, along with installing countless third party industry related platforms.

    Our business is founded on strong relationships. We invite you to visit us at the corner of www.BedfordandMain.com and be sure to check out our testimonials.

    Bedford and Main is a proud supporter of SIFMA and the Financial Services Institute.

    Consulting Specialties:
    • Conversion Specialist
    • Strategic Project Management
    • Clearing Firms and Securities Processing Platforms
    • FINRA Compliance Issues
    • Anti-Money Laundering and CEO Certifications
    • Firm Staffing and Restructuring
    • Contract Negotiations
    • Broker-dealer Start-ups
    • Selling “Shell” Firms and other Mergers & Acquisitions Activity
    Our clients appreciate how valuable it is to work with a consultant who has held the Series 3, 7, 24, 27 and 63 and is a FINRA arbitrator and an Anti-Money Laundering specialist. Moreover, the insights we provide resulting from our securities expert witness engagements often prove invaluable.

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    Bob Lawson, Securities Expert & FINRA Arbitrator
    3800 American Boulevard West, Suite 1110
    Bloomington MN 55431-4460
    USA
    phone: 800-741-0704
    fax: 952-835-1504
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    Barrington Capital Management, Inc. provides customized financial solutions for unique financial challenges and objectives. Their expertise is in the development, implementation and ongoing management of a customized and diversified investment strategy. Barrington's mission is to assist in building, enhancing, and protecting personal wealth and maintaining financial security.

    Robert Lawson Wealth Manager Expert PhotoPresident and Chief Executive Officer, Bob Lawson, has over 30 years of financial services experience as an Investment Advisory and Insurance Agency Executive, Securities Principal, and Options Principal. Bob proudly serves as an industry arbitrator for the Financial Industry Regulatory Authority (FINRA) and the National Futures Association (NFA), a Certified Fraud Examiner (CFE), ERISA (3)-21 Fiduciary, and an Accredited Investment Fiduciary.

    In addition to teaching advanced investment strategies and Retirement Planning classes throughout the year, Bob is widely sought as a keynote speaker for current financial events, markets, and personal financial planning topics. Bob Lawson has special expertise in stock options and has presented the following Options Industry Council (OIC) seminars to retail and industry professionals throughout the United States:
    • Options Basics
    • Options Intermediate
    • Advanced Options
  • Covered Calls
  • Options Spreads
  • Option Volatility
  • View Bob Lawson's Expert Witness Profile.
    7/11/2017 · Securities
    In the securities brokerage industry, "selling-away" refers to the prohibited practice of an Associated Person effecting or soliciting the sale of securities or investment products not held or approved with whom the broker is affiliated without prior written consent. FINRA regulators have seen a steady flow of selling-away cases over the years involving registered representatives who are being targeted by issuers, promoters and marketing agents to sell their nontraditional investment products to their retail customers. In many instances, promoters of these products are marketing them as non-securities products that do not have to be sold through a broker-dealer by a registered person. In a significant number of cases, associated persons have sold these investments to their customers away from the broker-dealer and without firm approval as required by FINRA Rule 3270. Selling-away often occurs in an independent branch or a satellite office, where Associated Persons are removed from the day-to-day oversight and supervision of their brokerage firm's compliance department.

    9/23/2015 · Finance
    I receive phone calls throughout the year from attorneys who have taken on their first FINRA case and they frequently are unaware how the FINRA Dispute Resolution process differs from other venues. I thought it would be helpful to provide a quick overview for new participants and a refresher for those more experienced securities attorneys on how the FINRA Arbitration and Mediation process works.

    8/26/2015 · Finance
    In FINRA-related cases many attorneys see discovery requests objected to by opposing counsel. Typically, opposing counsel objects to discovery requests citing that items requested are either "overly broad, vague, or ambiguous", or "impermissible per FINRA's Code of Arbitration Procedure". However, despite opposing counsel's reasoning, many objections to discovery requests are irrelevant and do not hold up in regard to FINRA's Code of Arbitration Procedure. Attorneys should not be intimidated or discouraged by these objections, but rather should understand that FINRA's guidelines concerning arbitration allow for most applicable and reasonably obtainable discovery information to be delivered.