Foley Partner Richard Wallace authored an article titled “FINRA Proposes New Suitability and ‘Know Your Customer’ Rules” in the 3rd Quarter 2009 issue of TIC Talk Quarterly. Wallace discusses the Financial Industry Regulatory Authority’s (FINRA) proposed rules for suitability and know-your-customer obligations and their implications for tenant in common (TIC) transactions. He adds that the proposed rules are likely to be accompanied by increased supervision and enforcement, noting that broker-dealers will need to be able to not only demonstrate appropriate policies and procedures with respect to determination of suitability, but also adequate training, supervision and disciplinary action with respect to licensed professionals.
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