In a recent column I called the SEC out for its appalling dereliction of duty in refusing to decide administrative appeals from enforcement sanctions imposed by the agency’s administrative law judges (ALJs)….
In my research for that column, I largely ignored the SEC’s parallel appellate docket: Appeals from enforcement sanctions imposed by the so-called self-regulatory organizations (“SROs”), primarily the Financial Industry Regulatory Authority (“FINRA”). I naively assumed this parallel docket was still operating business as usual. After all, appeals from SRO decisions are typically far less complicated that decisions from SEC ALJs, with less egregious conduct alleged, less paperwork in the administrative record, and lighter sanctions imposed.
Upon closer look, however, it turns out that appeals from SRO sanctions are nearly as stalled as those from ALJ sanctions, with SEC decisions almost as sporadic.
Source: (22) The SEC’s Other ‘Hotel California’ Docket | LinkedIn