Broker/Dealer Branch Offices
There Are Three Types – Can You Name All Three?
by Warren Forest
As anyone who has been in the securities business for any length of time knows, there is nothing simple about this industry. In
fact, some have gone on to say that simplicity and the brokerage business are mutually exclusive terms. One good example of this is how branch offices are defined.
Branch locations, or offices, are often essential in building a vibrant and flourishing business enterprise. McDonalds certainly could not advertise that it has sold billions and billions of hamburgers if it had to rely on just one store. In much the same way, brokerage companies often find it advantageous to have multiple locations.
Multiple offices can do many things for a company. By providing geographic dispersity they allow one to reach many more prospects. Decentralization also allows for sales persons to be physically available to clients that they service. Branding and marketing efforts are enhanced through branch operations. Regional and national presences can be made. Various business models can be employed through branch operations, such as franchising.
Now in every other type of business, a branch office is a branch office, plain and simple. Not so in the world of broker/dealers. For, in this world, there are three distinct types of branch offices. Each type has permitted activities, levels of supervision and required duties attached to it.
The first type of branch office is an Office of Supervisory Jurisdiction, or OSJ. OSJ’s are the highest level of branch office, and therefore, many high level functions are permitted to occur at an OSJ.
There are seven distinct functions that must happen at an OSJ branch: 1) Order Execution and Market Making; 2) Structuring
of Public Offerings or Private Placements; 3) Maintaining Custody of Customer Funds and/or Securities; 4) Final Acceptance/Approval of New Accounts on Behalf of the Member; 5) Review and Endorsement of Customer Orders; 6) Final Approval of Advertising or Sales Literature; and, 7) Responsibility for Supervising the Activities of Persons Associated with the Member. Not every member firm will conduct business in each of these functions, but if you are doing any of them, the location
better be registered as an OSJ.
The second type of office location is simply known as a Branch Office, or non-OSJ. A non-OSJ branch office is defined as any
location where one or more associated persons of a member regularly conducts the business of effecting any transactions in, or inducing, or attempting, to induce the purchase or sale of any security, or is held out as such, and does not conduct any of the seven activities permitted to happen at an OSJ.
If you are selling securities, or are trying to do so, and you are not doing any of the functions that are permitted to occur at an OSJ, then your location is simply a branch office. A little different from the norm, it is a location where sales functions are allowed, and a location where certain activities can never happen.
Now here is where things start to get a little more complicated. The third type of branch location is known as the “Non Branch” location, or NBL.
There are seven exclusions that define an NBL: 1) Any location established solely for customer service and/or back office
functions; 2) Any location that is the associated person’s primary residence; 3) Any location that is used for securities business less than 30 business days per calendar year; 4) Any office of convenience where associated persons occasionally, and exclusively, meet with customers by appointment; 5) Any location from which an associated person effects no more than 25 securities transactions in one calendar year; 6) The Floor of a registered national securities exchange; and, 7) A temporary location established in response to the implementation of a business continuity plan. * Business days are considered to be working at the NBL for four hours or more.
Any office that supervises the activities of associated persons conducting business as an NBL is considered to be a branch office. And each and every branch location must undergo a self inspection by the Member Firm. Exactly how often does the internal inspection have to occur? Well, that depends on how the office location is defined.
OSJ branches and non-OSJ offices that supervise one or more NBL’s must undergo an internal inspection at least once a year. Non-OSJ offices that are not responsible for supervising associated persons must be physically inspected at least every three years. And, NBL’s need to be inspected on a regular periodic schedule with no particular time-frame required.
Opening a branch office is not an automatic event, as firms that desire to have multiple locations must be approved by FINRA to do so. While the rules allow very limited flexibility in this area, typically increasing branch locations, as well as, the number of permitted personnel to staff the locations, is handled pursuant to a Continuing Member Application.
A formal request must be made, and the firm must evidence its ability to implement the changes. This is done by demonstrating
the supervisory system that will be in place, furnishing the procedural changes that will be made and designating specific individuals that can show experience in managing branch office locations.
FINRA also likes to see a minimum level of supervision in place. That minimum level is one designated principal, usually a Series 24 General Securities Principal, for every ten registered representatives that require supervision. Sometimes firms may need a higher level of supervision, such as, one designated principal supervising less than ten individuals.
As the complexities of branch office rules, requirements and regulations indicate, FINRA does not take these activities lightly. Many firms have made the mistake in the past to grow rapidly through geographic dispersion, and neglect to oversee the actions that occur at remote locations.
Firms that make sure that they have qualified experienced branch managers in place, and clearly establish the lines of responsibility, will do much to deflect the adverse actions that could otherwise occur. Coupling the people with quality procedures can do much to ensure that branch office operations will be a successful part of a firm’s business model.
*Please note that these exclusions are highlighted from the FINRA Rule 3010. To ensure that your location meets one of the
standards of an NBL, please seek professional advice.
Posted by: editor May 19, 2011
All-Public Arbitration Panels
Is There Fairness Without Representation
by Warren A. Forest
Virtually all security industry disputes are decided through an arbitration process rather than through litigation. Instead of having a judge hear a grievance and render a decision, customers and firms elect to have arbitrators listen to their dispute and grant an award to one party or the other.
Historically, most arbitration panels are composed of three members. Two of the panelists are “public” arbitrators meaning that they derive no income from, and have no direct ties to the security industry.
The third panel member is an “industry” arbitrator, and this person is tied to, and derives a significant portion of their income from the securities industry. More importantly, the industry arbitrator is familiar with industry rules, laws and regulation, and can lend considerable insight into often complicated issues that arise during the course of an arbitration hearing.
Unanimous decisions are strongly encouraged in arbitration proceedings. However, a majority decision will prevail, and is enough to render an arbitration award.
On February 1, 2011, FINRA announced that the SEC approved its proposed rule change to allow customers in all FINRA arbitrations the option to have an all-public arbitration panel. The amended rule will apply to all customer cases in which a list of potential arbitrators has not yet been sent to the parties.
According to Mr. Frank Ketchum, FINRA Chairman and Chief Executive Officer, “this change will give investors an additional choice in selecting their arbitrators when they file claims. We believe that giving investors the ability to have an all-public panel will increase public confidence in the fairness of our dispute resolution process.”
FINRA sought the rule change shortly after the arbitration results were tabulated for 2007, which was the worst year for investors that had their disputes decided by arbitration over the last six years. Securities firms prevailed in their cases nearly 60% of the time in 2007. Coincidentally, during the pilot program that soon ensued, customers chose all public panels nearly 60% of the time.
There are over five thousand arbitration cases filed every year. Yet, the pilot program to effect this rule change included the participation of only fourteen member firms, which is less than half-a-percent of the firms involved in an arbitration in any given year.
In the subsequent years, investors increasingly prevailed. In 2009, customers won almost 45% of their cases, and in 2010 the odds of a customer winning an arbitration case was just shy of 50%. FINRA was still concerned about perceptions, and claimed that “investors regularly accepted a non-public (industry) arbitrator, but the ability to have an all-public panel will increase public
confidence in the fairness of our dispute resolution process.”
Securities arbitration has a long history in the United States. Disputes between member firms, and between member firms and registered persons, must be decided through arbitration.
Grievances between member firms and customers can be resolved through arbitration as long as both parties use a pre-dispute
arbitration agreement where both sides voluntarily agree to arbitrate any dispute before any dispute actually arises. The use and validity of Pre-dispute Arbitration Agreements was upheld by the United States Supreme Court in Shearson v. MacMahon, 482 U.S. 220 (1987).
Arbitration is a preferred method for dispute resolution because it is typically faster, simpler and less expensive than litigation, most certainly for the claimants. Since almost all customer cases are handled on a contingency basis, the customer usually pays nothing until their case is decided.
The downside to arbitration is that you only get one shot at having your case heard. Since arbitration is binding, the grounds for
vacating an award are extremely few, therefore, virtually all awards rendered are final, and cannot be appealed.
The vast majority of customer initiated disputes against member firms involve only a few allegations. These allegations are suitability, excessive transactions, excessive commissions, negligence, and failures to supervise.
While the allegations are the same, customers historically make these allegations only when there is a monetary loss. In falling markets, arbitration cases soar, in rising markets they diminish. It becomes even more important during times of increasing arbitration cases that panels be as knowledgeable and informed as possible.
Arbitration is a forum of equity not a court of law. In recognition of this, the perception of equity is equally important as is the actuality of equity. That is why there have historically been two public arbitrators instead of two industry arbitrators on three member arbitration panels.
Security arbitrations often involve complex issues that an industry panelist can shed light on and explain to the public members of the panel. Without this important input, the process, let alone the perception of the process can be critically flawed.
While it is still extremely early to determine the outcome of this amendment on all of the parties involved, member firms, and customers alike, should be extremely wary of the change. Arbitration cases that are not adequately heard and understood by panels will have an adverse effect on all participants involved.
Member firms have never had equal representation on arbitration panels. To deny them of any representation at all has at least the perception of defeating any chance of equity for them. Since arbitration is a voluntary process, firms may want to consider litigation in lieu of arbitration until the perception of equity is restored for them.
Posted by: editor March 22, 2011
Suitability and Knowing Your Customer
The Rules Are About To Change
by Warren A. Forest
Anyone that has been in the securities business for any length of time learns two essential elements very early in their career. These two elements go hand-in-hand in building a successful foundation to support all sales efforts directed toward customers.
First, a registered representative needs to “know” their customer. Second, all transactions that a registered representative recommends to a customer must be suitable for them.
These concepts have been generally understood to be critical for ensuring your customers’ financial interests are protected, the customers are treated fairly by the security professionals they are relying on, and the highest standard of ethical treatment is in place. While these two provisions have been required for some time now, recently FINRA has put in place additional definitions and requirements to better identify responsibilities and strengthen the present rules.
The new provisions are effective on October 7, 2011, and it is extremely important that registered individuals and brokerage houses become familiar with the new rules. These enhanced rules will require changes in procedures for dealing with customers, documenting changes to meet the additional information needed, and more recordkeeping of documentation evidencing compliance with the new rules.
The first element is a requirement that brokers “know” their customers. Now FINRA is not suggesting that brokers “know” their customers in a biblical sense. Instead, firms and registered representatives must use “reasonable diligence” and attempt to know the “essential facts” affecting each and every customer.
Reasonable diligence means that one must demonstrate that they have made a professional attempt to gather the information. In other words, if clients do not make information available, or thwart the information gathering attempt, Herculean efforts to otherwise get the information do not need to be made.
Essential facts are “those required to effectively service the account, act in accordance with any special handling of the account, understand the authority of each person acting on behalf of the customer, and comply with applicable laws, regulations and rules. In other words, you must have enough information about your customer to both support and defend the recommendations that you make to them.
When do you need to “know” your customer? A broker must know their customer at the very beginning of the relationship, and the requirement has to continue throughout the relationship. It does not end after the account is opened. Many things will change over time, and these factors need to be constantly updated if they will affect financial recommendations made to a customer.
A broker’s obligation to know their customer is independent of whether or not a broker makes a recommendation. Firms and brokers need to demonstrate that they have enough information on hand regarding their customers to support any sales to them, even if they never make a sale.
The second element is suitability of recommendations. Or, to paraphrase the FINRA suitability rule, “a firm or associated person is required to have a reasonable basis to believe that a recommended transaction or investment strategy involving a security, or securities is suitable for the customer, based on the information obtained through the reasonable diligence of the member or associated person to ascertain the customer’s investment profile.” The customer’s investment profile “includes, but is not limited to the customer’s age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance and any other information the customer may disclose to the member or associated person in connection with such recommendation.”
It is important to understand exactly what a recommendation is. Specifically, a recommendation is any information communicated to a customer that could result in a triggering event happening, such as a purchase, or sale, of a security. Like the requirement to “know” your customer even if a purchase or sale never occurs, with respect to suitability, it does not matter whether an actual triggering event ever occurs. Even if a purchase or sale never happens, both firms and brokers must make sure that the recommendation itself is suitable.
The new rule requires that even more information be captured and documented concerning the customer. In addition to financial situation, financial needs, tax status, other investments and investment objectives, other factors such as age investment experience, risk tolerance, time horizons and liquidity needs must be added.
But, that is not all as there is the ubiquitous “catch all” category, any other information the customer may disclose to the firm or associated person in regards to the recommendation. As FINRA believes that each required information is essential for a determination of suitability, each firm and their associated persons must document their basis for not including, or capturing, a required piece of information.
The new suitability rule also reflects three main suitability obligations. These are reasonable basis suitability, customer specific suitability and quantitative suitability.
Reasonable basis suitability basically means that a broker, after doing their homework concerning an investment vehicle, also known as “reasonable diligence” would have a reason to believe that the investment is suitable for at least some investors. At the very least, in order to demonstrate reasonable basis, one should understand the particular risks and rewards associated with the recommended strategy or investment.
Customer specific suitability means that a broker must have enough information to insure that a specific recommendation is suitable for the specific customer based upon that customer’s investment profile. Firms and brokers must, therefore, insure that they capture all of the required informational fields that now must be documented in order to demonstrate compliance with the rule.
Quantitative suitability or “more is not necessarily better” suitability, requires a broker to demonstrate that a series of recommended transactions is still suitable, even if an isolated transaction is appropriate. If you have a number of transactions involving the same security, and the same customer, you need to show that the transactions in total are not excessive, and, therefore, unsuitable for the customer.
Clearly, the sales process is going to be more involved than ever before under the new rules. While requirements can appear to be burdensome and a nuisance, the enhanced definitions and additional information needs should be viewed as marketing opportunities. For the know your customer and suitability rules will give registered representatives ample chances to stay in close touch with their customers, and closer communications with customers invariably leads to increased sales.
Posted by: editor February 8, 2011
Securities Arbitrations – Part II of II
You have recently received a Statement of Claim from one of your customers demanding an arbitration hearing to resolve a dispute between them and you. You may have already received a complaint from the customer about an investment you recommended that did not perform up to the level of their expectations. Or, the Arbitration Claim may have simply come out of the blue, completely unexpected. Whatever the circumstances that caused the situation to occur, immediate action on your part is now required.
Although a firm may receive an Arbitration Notice unexpectedly, without any advance warning or knowledge, this is rare. In all likelihood, there is usually something that will indicate a customer’s dissatisfaction with their investment. Typically a number of phone calls and complaint letters precede an Arbitration Action. All too often, firms take inadequate steps to mitigate and, or resolve the situation, or they just simply choose to ignore things, and mistakenly hope that the problem will somehow disappear.
When the dollar amounts of the losses are large, as they typically are in the vast majority of cases, ignoring the problem will not make it go away. The end result is the receipt of the Arbitration Claim. One of the first things that need to occur is preparing an Answer to the Statement of Claim.
Before you respond to the claimant and FINRA Dispute Resolution, you must make sure that all required notifications pertaining to the arbitration are made to FINRA Regulation. That means that Form U-4 amendments are created disclosing the matters. It is important to note that even if a Registered Representative is not named as a claimant to the dispute, their Form U-4, or Form U-5 if they were terminated within the last twenty four (24) months, is updated to reflect the complaint or arbitration.
Depending on the nature of the dispute, the firm’s Form BD may need to be amended as well. While most customer initiated disputes do not result in situations that require disclosure at the company level, management should always take the initiative and verify whether a Form BD amendment is needed or not.
Another area that must be considered is the notifications required pursuant to FINRA Rule 3070. Rule 3070 requires that notifications pertaining to certain events, including complaints and arbitrations, be electronically transmitted to FINRA. Many times, in the heat of the moment, the required regulatory notifications are made late or forgotten entirely, and this can result in fines and sanctions against the firm, in addition to any adverse awards rendered directly as a result of the actual arbitration.
Now that the housekeeping efforts have been completed, all required filings have been properly submitted to FINRA, and have been reviewed by designated principals and retained as part of the firm’s records, it is time to move on to answering the claimant’s Statement of Claim. The Statement of Answer is a required response, but when creating it you should never lose sight of your intended audience. That audience is the Arbitration Panel.
Arbitration Panels can be composed of one panel member, or three panelists. Usually the monetary losses realized by a customer that initiate the dispute are large enough to warrant that the matter will be heard by a three- member panel. When a dispute involves a customer and a FINRA member, the three-member panel will be comprised of two non-industry panelists and one industry panelist.
Invariably one will hire an attorney to represent them for the arbitration. Unlike a court of law, however, where you must have legal counsel, unless the court action involves a small claim, you do not need an attorney to represent you in an arbitration hearing. You can be a “pro se” respondent, and answer on your own behalf. In most cases this is not recommended, but in some instances it can be an effective strategy as arbitration panels usually will give more leeway to a pro se respondent than to an attorney.
As the arbitration process is a forum of equity, and not a court of law, all documents, representations, verbal and written communications, in other words everything you present on your behalf should be directed to that fact. You should do away with presenting endless citations of case law, legal precedents and legalese. Instead, all information should be presented in plain easy to understand English.
Another mistake is made in the amount of documents presented and the amount of time estimated to present the case. Many times numerous voluminous binders are compiled that panelists must repeatedly juggle as they refer to various papers during the course of the hearing. Often, there is a veritable overkill of information presented. Although one or the other side will object to documents or testimony given as evidence, due to the nature of the arbitration process almost everything presented will be accepted by the panel, and they will give evidence the “weight that it merits.” Burdening arbitration panels with too much unneeded information can be worse than not giving them enough.
Many cases can be decided in two-thirds to half-the-time they are given. All too often, the parties will schedule four or five day hearings. The vast majority of customer claims allege the same infractions, such as unsuitable transactions, unauthorized trading, churning and failures to supervise. If the claim has merit, or if the defense of the claim is valid, it typically becomes apparent to arbitration panels early on in the process. The best approach to an effective presentation to an arbitration panel is to follow the kiss principal and “keep it simple and straightforward.”
We are visual creatures. A much more effective use of cornerstone evidence is to display it in front of a panel at all times rather than have it buried within a binder. By cornerstone evidence we are talking about such things as New Account Forms, Disclosure Letters, Speculative Trading Authorizations, etc. To the extent that will bolster the case, use them largely. Largely means just that, have the documents maximized to three foot by five foot displays. And, let them sit in the hearing room for the entire length of the arbitration. Refer to them often when making your case, or defending against allegations.
The effect on panels can be dramatic. Since the displays will be ever present, they can do work for you even when you are not talking. If the client established risk tolerances and time horizons that coincide with the investments in dispute, or if we have documents, or letters that bolster your side of the disagreement, it makes sense to let the panelists see that information in a large format.
Panelists, unlike juries, will begin talking about the case amongst themselves at the first opportunity to do so. How effective one is in establishing the strength of your position early on often means the difference between success and failure. Due to the binding non-appealable nature of arbitration, giving written reason explaining the basis behind an award is discouraged, and rare to see. Awards can be paid out over time, but have to be booked in their entirety on a Broker/Dealers financial statements. The unknown aspect, the binding nature of the award, and the immediate requirement to record the whole amount of the award makes it even more important to establish the strongest position you can as quickly as you can.
Due to these conditions of arbitration, another option to consider is litigation. Litigation is more costly for firms, but it is also more costly for claimants. While most arbitrations are handled on a contingent basis by claimant’s counsel, litigations typically are not. Lastly, litigation is appealable so that you can effectively get more than one day “in court” if you do not initially prevail. Claimants that jump at the chance to arbitrate may think twice if they have to litigate.
By the time a dispute escalates into an arbitration hearing, it is apparent that neither side has “clean hands”. If they did, the matter would have been settled long before the hearing. When questioned, both parties will conveniently suffer from SLOM Syndrome, or Selective Loss Of Memory. But, the fact will remain that both sides are remiss. The best chance of prevailing goes to the party that can establish a more credible position sooner than the other side does. The key to succeeding in arbitration is simple. Convince the panel that your position is right using clear, easy to understand evidence is all one needs to do.
Posted by: editor October 11, 2010
SECURITY ARBITRATIONS – PART I of II
How To Successfully Present Your Case
As the poet Robert Burns so aptly put it, “the best laid plans of mice and men often go astray.” Despite our good intentions, what we attempt to do does not always materialize. Depending on the ultimate outcome of events, our failings may leave us with unforgiving results.
When these events involve brokerage customers and the loss of their monies, often security arbitration is the end result. Since arbitration awards are binding, final and non-appealable, securities arbitration can certainly be considered to be an unforgiving process.
In prior newsletters, we have written extensively about the importance of keeping good records, of communicating effectively with customers and how to best handle customer complaints. Firms that have effective compliance programs, and adopt the proactive systems needed to successfully defend themselves, will minimize the probability that a customer dispute will escalate into arbitration.
When a complaint evolves into an arbitration claim, firms that have these same effective compliance measures in place will also minimize the chance that an adverse arbitration award will be rendered against them. In other words, proactive compliance will allow firms and associated persons to prevail in the arbitration forum.
The best arbitration is the one that never happens. If you can avoid the arbitration process, ninety-nine times out of a hundred it is best to do so. Often people get caught up in the process once it begins and get ensnared by the “principle” trap. They might think they should fight because their principles are infracted upon. As most attorneys will tell you, “principle” is the most expensive word in the English language.
If there is a way to resolve the dispute prior to arbitration, it is highly recommended that a resolution occur. If the matter can be settled amicably, it is often far less costly to do so. Unresolved disputes, as part of the arbitration process, can be directed to concurrent mediation, so that formal resolution efforts can take place even as the arbitration works its way forward in the system.
Unlike customers, arbitration will involve hard dollar costs for a broker/dealer and any associated persons named in a dispute. Firms will have to pay forum fees and hearing costs, and sometimes these costs are assessed even if the firm wins the case. Attorney representation, while not required for an arbitration case, is highly recommended. If you do not already know this, you will quickly find out once you find yourself named in an arbitration, that attorneys can be very expensive.
Most claimants (customers) on the other hand, do not have to pay upfront fees or expenses. Claimants are generally represented on a contingency basis by their lawyers. This means that they do not have to pay anything to their attorneys unless they prevail and receive a monetary award.
Numerous customer actions are arbitrated simply because claimants lost money due to market conditions, and not because the recommendations were unsuitable, fraudulent, or the principals failed to supervise the registered representatives properly. Unfortunately, all too often, firms do not have adequate resources or documentation in place to mount an adequate defense.
While arbitration on the surface may appear to be like litigation, or a court proceeding, there are huge differences in the process and philosophy of arbitration. Both sides, claimants and respondents (broker/dealers and associated persons) are invariably represented by legal counsel. There is a panel of arbitrators who effectively serve as judge and jury. But, there the similarities end.
Arbitration is a forum for equity, and is not a court of law. Many brokerage firms and their attorneys fail to note this. The distinction between arbitration and litigation, which if not thoroughly understood, can end with disastrous results. Legal counsel will often submit briefs which go into great detail citing case law. Attorneys will raise repeated vehement objections during hearings as if they were posturing before a jury. Many times neither side fully understands the nuances involved in the actual transaction that resulted in the hearing in the first place.
As a forum of equity, rules of evidence, and formal rules of the court do not apply. While there is a discovery process involved in arbitration that is designed to uncover factual evidence, the strict rules of discovery that apply in court, do not apply to arbitrations. Although there is an overall structure to the arbitration process, this structure is much less rigorous and controlled than a court proceeding.
If you are the unlucky recipient of a Notice of Hearing for an arbitration, take whatever steps you can to resolve it before the hearing. When resolution is not possible, then become as knowledgeable about the process as you can, for knowledge is power.
The first step in the arbitration process involves filing the Statement of Claim. The vast majority of customer’s Statement of Claims all cite the same infractions. We call these infractions the three U’s. That is the transactions were Unsuitable, Unauthorized, and Unsupervised.
When a customer makes these allegations they are basically saying that their broker sold them a security that was completely inappropriate for them. Furthermore, the sale occurred without their knowledge and/or permission, and no one in management knew about the transaction.
Other allegations will often be made as well, such as negligence, fraud and breach of fiduciary responsibility. Lack of fiduciary responsibility is a moot allegation since Broker/Dealers and their associated persons are legally not fiduciaries. In any event, these other allegations are but window dressing as the cases will ultimately hinge on you successfully defending yourself against the three U’s.
The task at hand then is to prove all of these customer allegations to be wrong. In order to do this one must first create a Statement of Answers and Defenses. The Statement of Answers and Defenses must thoroughly discuss the claimant’s Claims and describe why they are groundless. Proper account documentation and a good audit trail of the transactions are invaluable in building a credible defense.
One of the major faults with most Statements of Answers are they are written by attorneys for attorneys. They tend to be quite long, address complicated legal theories and cite numerous case law findings.
The problem with this is that the ultimate readers will be members of the arbitration panel who are charged with hearing and deciding the case. At least some of the panel, if not all of the panelists are not lawyers.
The best Statements of Answer are written in understandable English and are addressed to non-attorneys. They will succinctly answer all of the allegations, and will not rely on a preponderance of legalese to do so.
After all of the initial paperwork has been created and distributed to the parties involved, the next step in the process will begin. That is discussing the timetable for preparing and submitting evidence and scheduling dates for the hearing.
Our next newsletter will help you continue your knowledge base for arbitrations. We will thoroughly discuss the entire hearing process and will elaborate upon panel selection, pre-hearing sessions and the hearing process itself. Effective strategies for presenting a case will be reviewed, as well as alternatives to arbitration and the reasons why they should be considered.
Posted by: editor September 21, 2010
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