Sister Can You Spare A Dime?

Published Saturday, December 01, 2007

Want to borrow some money from a client? Yeah, sounds a little shady on the face of it, but maybe you have good reasons. Well, proceed with caution. NASD Conduct Rule 2370: Borrowing From or Lending to Customers is a fairly simple proposition: Registered persons may only borrow money from, or lend money to, a customer pursuant to their member firm's written procedures. But as a veteran industry lawyer, I've learned that it is precisely such seemingly uncomplicated rules that can turn into career-killing quicksand. If you want to engage in customer borrowing/lending, then you must confirm that ...

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