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Nondisclosure of FINRA 2023 Board Votes Is Hypocritical Lack of Corporate Governance Transparency

October 5, 2023

About a month ago, FINRA published a press release announcing the victors of the two unopposed Board elections without also announcing the number of votes cast. Oddly, FINRA refuses to announce the number of abstentions cast despite the fact that FINRA engaged a proxy solicitor to help FINRA meet the requirement of a quorum in the face of a call to boycott the elections. FINRA spent its members' funds on trying to force a quorum, and, as such, FINRA should disclose to its members the numbers of votes that the proxy solicitor was paid to obtain. Given FINRA's lack of transparency, the conversation now moves from "why" didn't the self-regulatory-organization timely disclose the vote tallies to "what" is the regulator hiding.

May 2023 Call for Boycott

In May 2023, I called for a boycott of all 2023 FINRA elections. The published goal of the boycott was to persuade the majority of FINRA Small Firms (1-150 registered representatives) to not return their firm's proxy. FINRA's most recent disclosure of 3,039 Small Firms required that 1,520 join the boycott:

[F]urther, until such time as FINRA demonstrates a sincere commitment to reform, all FINRA member firms should instruct their Executive Representative to not cast a vote for any candidate in any FINRA election by way of a boycott.

FINRA's Board of Governors is a lackluster amalgamation that is tone deaf to the legitimate needs of its smaller members and resistant to implementing the necessary reforms to protect the investing public and the industry's financial professionals. FINRA's Small Firm members represent some 90% of the membership but are gerrymandered down to about 13% of the Board Governors. Since the Small Firm Members are of no apparent consequence, I urge the Small Firm community to boycott all 2023 FINRA elections. Further, until such time as FINRA demonstrates a sincere commitment to reform, I urge all FINRA member firms to instruct their Executive Representative to not cast a vote for any candidate in any 2023 FINRA election by way of a boycott. 

[T]he goal of the boycott is to persuade 1,520 FINRA Small Firm Executive Representatives to not return their firm's proxy. . . .

The FINRA Small Firm community sent a message to FINRA by boycotting the petition phase of the 2023 Board elections; and, as a result, only one FINRA Small Firm candidate received enough petitions to move forward to fill one of the three Small Firm Governor seats. Those three seats amount to about 13% of the overall Board despite representing about 90% of the organization's member firms. Not much representative democracy with that bit of social engineering. Not much of an election when there's only one candidate running to fill one vacancy. There is no point in casting a worthless vote. It is a quiet, elegant form of protest. 

Troubling Proxy Solicitation to ABSTAIN

In August 2023, purported FINRA Small Firm Executive Representatives and industry compliance/regulatory consultants informed me that they had received (or were aware of) phone calls from a company that asserts it has been retained by FINRA for the purpose of contacting Executive Representatives eligible to vote for the Small Firm Governor. In response to my advocacy, some of the folks contacted by the caller had decided to "boycott" the 2023 Small Firm Governor election and did not return their proxy. When the caller contacting the representatives was informed of their decisions to boycott the election via the non-submission of a proxy, the caller purportedly pressed the representative to cast a vote in "Abstention." The caller allegedly suggested that they could opt to "not vote" by also casting a vote in "abstention." 

Undisclosed Impact on Meeting Quorum

Many of the representatives/consultants found the proxy solicitor's conduct odd given that one and only one candidate is running for the Small Firm seat. Why was FINRA apparently exerting so much pressure to secure a proxy in an uncontested election? The likely answer is that the unopposed candidate was going to win a majority of the votes cast; however, the boycott had gained enough traction to apparently threaten the satisfaction of the one-third quorum. The folks who contacted me about the pressure from FINRA's apparent proxy solicitor expressed concern that the caller never disclosed to them that a vote-in-abstention counted towards a "quorum," whereas the non-submission of a proxy did not. 

Apparently fearing that a majority of small firms had enrolled in the boycott and were not going to cast a proxy in this year's Small Firm Governor race, FINRA then did its best to save face by trying to ensure a quorum, which FINRA defines as "one-third of the members entitled to vote at the meeting shall be necessary and sufficient to constitute a quorum." As months of my published content prove, the boycott's goal was always to persuade more than half of FINRA's Small Member firms to NOT cast a proxy during the Board election -- NEVER was there a goal to prevent a quorum. That is merely FINRA moving goalposts to serve its own needs. Frankly, that's not the ethical posture we should expect from a regulator. It comes off as dishonest and manipulative. Further, the silence of each of the Governors when faced with FINRA's apparent effort to steer the election by encouraging a proxy solicitor to satisfy a quorum through misrepresenting (by omission or commission) the impact of a vote-in-Abstention is merely more proof that the Governors should resign en masse. 

1996's Troubling Election-Interference Legacy

In the SEC’s historic “REPORT PURSUANT TO SECTION 21(a) OF THE SECURITIES EXCHANGE ACT OF 1934 REGARDING THE NASD AND THE NASDAQ MARKET” (August 8, 1996)
https://www.sec.gov/files/litigation/investreport/nd21a-report.pdf, the federal regulator found, in part, that the NASD self-regulatory-organization (FINRA’s predecessor) had “violated Section 19(g) of the Exchange Act by failing adequately to comply with certain NASD rules and, without reasonable justification or excuse, to enforce compliance with the Exchange Act . . .” at Page 1 of the 21(a) Report. Further, “C. Other Areas of Regulatory Concern” set out four enumerated topics of which the third was “The Contested Election Process. “ at Page A-iii of the Appendix to the 21(a) Report [Ed: footnote omitted]:

3. The Contested Election Process

In the Report issued by the Rudman Committee in its review of the NASD's operations, the Committee discussed the NASD's District Nominating Committee and made particular reference to a contested election in 1994 in District 10.

The Rudman Committee stated:

[The NASD] addressed issues that arose on an ad hoc basis, and generally handled the election inappropriately - particularly insofar as NASD staff appeared to take sides in the matter. NASD officials have acknowledged that the election was mishandled.

The gist of the Rudman Committee's concerns arose out of two letters sent by the District 10 Nominating Committee, the first of which was on NASD letterhead, endorsing the candidacy of one person over the challenger. In addition, volunteers recruited by the NASD's District Nominating Committee actively campaigned in support of the successful candidate. The NASD's By-Laws only specifically authorize the Nominating Committee to select the regular candidate. The NASD, its committees and its staff should not in any way exhibit favoritism or partiality in such elections.

at Page A-83 of the Appendix to the 21(a) Report:

Unlearned Lessons?

If, in fact, FINRA member firms were pressured by the proxy solicitor to cast any type of vote in an election – be that for the uncontested candidate, or to cast a vote-in-abstention rather than not cast any vote – that was unacceptable. The privilege of voting includes the right to not vote. The uncontested 2023 Small Firm Governor's election should not have provided cover for any inappropriate conduct seeking to harvest votes for the sole candidate or votes in abstention. In light of the call to boycott this year's FINRA election by not submitting a proxy, FINRA's apparent push to secure the one-third quorum by using a proxy solicitor seems an unsavory attempt to rig the election. Given the totality of the circumstances, it was incumbent upon FINRA to maintain a disinterest and a distance appropriate for its role as a regulator. FINRA mishandled the now-completed 2023 election, just as NASD did some 30 years ago when it exhibited "favoritism or partiality in such elections."

August 23, 2023 FINRA Weekly Update

Perhaps in response to my published criticisms of FINRA's apparent interference in the 2023 Small Firm Governor's election, the regulator published this in "FINRA Weekly Update / August 23, 2023 / Volume 34":

Guidance

All small and large firm members are encouraged to vote in the current Board of Governors election which concludes on September 6, 2023. Election Notice 8/7/2023 contains more information on the candidates and the election process.

Although the small and large firm elections are uncontested, FINRA must still meet its quorum requirement to finalize the elections.

A proxy solicitor was engaged by FINRA to contact firms to ensure that they received the proxy card, to encourage broad participation in the election and to help FINRA meet its quorum requirement. FINRA’s election agent is also sending email reminders to the executive representative of each firm with voting instructions (if you have your proxy, you can vote online here).

If you have questions or need a replacement proxy, please email the Office of Corporate Secretary or call (202) 728-894

FINRA cynically asserts that the "proxy solicitor was engaged by FINRA to contact firms to ensure that they received the proxy card, to encourage broad participation in the election and to help FINRA meet its quorum requirement." Notably, there is no mention in that quote of any engagement of the solicitor to pressure firms to vote their proxy -- but according to reports, that's exactly how many firms perceived the so-called "contact."

It's one thing to confirm whether a firm had received a proxy card. It's another thing to press firms to submit the proxy card -- and all the more so when the election at issue is UNCONTESTED with one and only one candidate. 

Absent from FINRA's Weekly Update is any acknowledgment that in this year's uncontested Small Firm Governor's election that a call for boycott was raised and that only one candidate emerged from the petition process. This is a critical distinction because the only possible outcome of ensuring a quorum in an uncontested race is that the sole candidate would be certified the winner -- one would be hard pressed to imagine a scenario more indicative of FINRA showing inappropriate "favoritism or partiality in such elections."

In an era when talk about stolen elections and corrupted voting is all the rage, Wall Street's preeminent self-regulator asks the industry and the investing public to believe that it has an unfettered right to ensure that a quorum is met in order to "finalize" its Board of Governors election. Given the context, FINRA is asking us to accept a self-serving, disingenuous excuse to provide cover for its mishandling of an uncontested Board election. And this from a Wall Street regulator that has amassed a history of prosecuting and sanctioning brokerage firms and brokers who resort to omissions and commissions of facts in an effort to fraudulently finalize securities offerings.

I challenge FINRA to produce any prior notices containing a similarly worded comment along the lines that the organization "must still meet its quorum requirement to finalize the elections." Additionally, FINRA excuses the proxy solicitor's efforts as merely designed to "encourage broad participation in the election and to help FINRA meet its quorum requirement." Really? That's all that's going on here?? Just some old-fashioned encouragement??? 

Form TCR Filed

In August 2023, I filed a Form TCR with the SEC and asked the federal regulator to investigate FINRA’s conduct of the 2023 Small Firm Governor election. In furtherance of such an investigation, the SEC should require FINRA to conduct a statistical analysis to determine whether the number of votes cast in "Abstention" in this year's Small Firm election have meaningfully increased from prior years; and, as such, would confirm the reports of pressure from the proxy firm to elicit a vote in abstention rather than accept a representative's decision to boycott the election by not casting any vote.

Additionally, the SEC should demand production of all communications between FINRA and its officers/Board, on the one hand, and the proxy solicitation firm and its agents, on the other hand. Such an inquiry should be designed to determine whether any guidance was provided by FINRA to the proxy firm in terms of how "abstentions" should be solicited and what disclosures were warranted about the impact of such abstentions on validating the uncontested election per satisfaction of the requisite quorum.

If there was pressure by FINRA on its member firms to vote in abstention, I would ask that the SEC deem FINRA's actions via its proxy solicitor as the inappropriate intrusion into the election process. Consequently, the SEC should decertify the results of such an election and demand a new election. Further, I would urge the SEC to impose significant monetary penalties upon FINRA and demand substantive election-rules reforms. 

Tarnished Election

As one of the founders of the NASD Dissident/Reform Movement (now the FINRA Dissident/Reform Movement), and as a member of the 1998 slate of the first four petition candidates to successfully challenge the self-regulatory-organization's process of anointing its industry Board members, I am a fervent proponent of robust, contested elections as a means of democratizing FINRA's Board.This year's Small Firm Governor election is so tarnished that even if the number of votes cast (including abstentions) rises to the one-third quorum, the victorious candidate will never be viewed as legitimate. FINRA's Board of Governors should declare the 2023 election invalid and order a new vote without the interference of the proxy solicitor. Shamefully, no sitting Governor has spoken out against FINRA's election interference; but, in truth, we have come to expect such equivocation from this lackluster Board.

The "Results"

On September 6, 2023, FINRA declared the victories of two unopposed candidates in its Board of Governors elections; however, a month later, FINRA still declines to publish the tally of the votes cast for each candidate and, critically, fails to publish the tally of votes cast in "Abstention." "FINRA Announces Results of Governor Elections" (FINRA  / September 6, 2023)
https://www.finra.org/media-center/newsreleases/2023/finra-announces-results-governor-elections

FINRA's conduct seems more in the nature of a cover-up than the robust disclosure expected from a regulator: so much for high standards of corporate governance. Worse, no sitting FINRA Governor has spoken out against the organization's unacceptable failure to promptly disclose the actual votes in the 2023 election; but, in truth, such equivocation is all too characteristic of this lackluster Board.

FINRA's oft-voiced advocacy for ESG and diversity/inclusion and ethical corporate governance comes off as insincere and hollow when the self-regulatory-organization fails to timely release the actual vote tallies in its elections -- all the more so when a given election is the subject of a boycott and the two Board candidates ran unopposed. FINRA's duplicity is indefensible given this assertion in "Board Reaffirms FINRA’s Financial Guiding Principles; Receives Updates on Regulatory Operations" (Report From FINRA Board of Governors Meeting – September 2023 / September 26, 2023)
https://www.finra.org/media-center/newsreleases/2023/report-finra-board-governors-meeting-september-2023

FINRA’s Board of Governors met on September 13-14 in Philadelphia. In addition to continuing discussions around FINRA’s Regulatory Operations, the Board reaffirmed FINRA’s Financial Guiding Principles.

“Transparency around FINRA’s finances benefits everyone in our industry,” said FINRA Board Chair Eric Noll. “Through reaffirming the Financial Guiding Principles, the Board continues to provide clarity and direction on how FINRA can best fulfill its regulatory mandate.” . . .

Transparency? Transparency, Chair Noll -- seriously?? Where is the transparency, where is the clarity, what is the direction in your failure to fully disclose the vote tallies in your 2023 Board elections?

It is now over a month since published a press release announcing the victors of the two unopposed Board elections without also announcing the number of votes. More ominous, FINRA refuses to announce the number of abstentions cast despite the fact that FINRA engaged a proxy solicitor "to contact firms to ensure that they received the proxy card, to encourage broad participation in the election and to help FINRA meet its quorum requirement." FINRA spent its members' funds on trying to force a quorum in the face of a boycott, and the regulator should disclose to its members the numbers of votes that the proxy solicitor was paid to obtain. Given FINRA's lack of transparency, the conversation now moves from "why" didn't the self-regulatory-organization timely disclose the vote tallies to "what" is the regulator hiding.

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