If you have suffered financial harm as a result of investing in variable universal life insurance contracts or mutual funds with Farmers Financial Solutions, LLC, contact FINRA arbitration lawyers Iorio Altamirano LLP for a free and confidential consultation.

Farmers Financial Solutions, LLC

Farmers Financial Solutions, LLC has been a registered brokerage firm since August 200. Farmers Financial, headquartered in Westlake Village, California, sells variable universal life insurance contracts, mutual funds, 529 Plans, and annuities. The firm has approximately 4,300 registered representatives (brokers) and approximately 3,800 branch officers.

FINRA Letter of Acceptance, Waiver, and Consent No. 2017052173001

On June 21, 2021, Farmers Financial agreed to a censure and $100,000 fine after FINRA alleged that from at least June 2016 through December 2018, Farmers Financial failed to establish and maintain a reasonably designed supervisory system to achieve compliance with applicable securities laws and regulations with respect to its VUL business.

FINRA also alleged that from least June 2016 through December 2018, Farmers Financial failed to establish and maintain a reasonably designed supervisory system to achieve compliance with applicable securities laws and regulations with respect to its VUL business.

Applicable FINRA Rules

FINRA Rule 3110(a) requires that FINRA members “establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules.” The firm needs to supervise for compliance with FINRA Rule 2111, which requires that a member “have a reasonable basis to believe that a recommended transaction or investment strategy involving a security or securities is suitable for the customer,” including “a reasonable basis to believe that the customer has the financial ability to meet such commitment.”1A violation of FINRA Rule 3110 constitutes a violation of FINRA Rule 2010, which requires member firms to “observe high standards of commercial honor and just and equitable principles of trade” in the conduct of their business.

Farmers Financial Failed to Reasonably Supervise Its VUL Business

A variable universal life insurance contract (VUL) is a permanent life insurance policy that contains both insurance and securities features. Variable universal life insurance contracts are long-term products that can provide coverage for the life of an insured and offer a death benefit payable on the death of the insured. VULs also have an investment feature called the “cash value,” which refers to the underlying value of the investment portion of the VUL. VUL premium payments, which are paid throughout the life of the VUL, are allocated to investment subaccounts in order to increase the cash value. Monthly charges, including the cost of insurance coverage and administrative fees, are deducted from the product’s cash value. The cash value of the VUL may increase or decrease based on the performance of the investment subaccounts. A VUL lapses if the customer stops paying premiums and the cash value is insufficient to pay the monthly charges. If a VUL lapses, the customer is left with no insurance and no investment payout.

FINRA alleged that from June 2016 through December 2018, Farmers Financial failed to establish and maintain a reasonably designed supervisory system to achieve compliance with applicable securities laws and regulations with respect to its VUL business. Specifically, FINRA alleged:

• From June 2016 through December 2018, Farmers Financial sold approximately $30 million in VULs, constituting approximately 30% of Farmers Financial’s revenues.
• During this period, Farmers Financial failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws and regulations with respect to its VUL business.
• Specifically, the firm had information indicating that VUL policies were lapsing but failed to take reasonable steps to identify why the lapses occurred and whether the sales of VULs to the particular customers were suitable and to monitor the registered representatives involved.
• If a VUL lapsed within certain time parameters set by the issuer, the VUL issuer would claw back the commission paid to the firm and registered representative.
• The firm’s Finance Department, as well as the registered representative’s direct supervisor, were aware of when these clawbacks occurred. This information, however, was not shared with the firm’s principals, who reviewed proposed VUL transactions.
• In addition, the firm did not have any exception reports or other tools that would enable it to identify representatives with high lapse rates.
• Therefore, the firm could not identify and follow up on registered representatives with high lapse rates or unusual transaction patterns, such as selling new VULs to customers whose previous VULs had lapsed.
• As a result of this unreasonable supervisory system, the firm did not identify a registered representative who had been working at the firm for two years, sold over 200 VULs, and amassed a lapse rate of approximately 40%.
• The same representative also made repeat sales of VULs to customers whose VULs had previously lapsed, which the firm’s system did not identify.

Accordingly, FINRA concluded that Farmers Financial violated FINRA Rules 3110(a) and 2010.

Framers Financial Failed to Reasonably Supervise its Mutual Fund Business

FINRA alleged that from least June 2016 through December 2018, Farmers Financial failed to establish and maintain a reasonably designed supervisory system to achieve compliance with applicable securities laws and regulations with respect to its VUL business. Specifically, FINRA alleged:

• The vast majority of mutual funds sold by Farmers Financial in 2016 and 2017 were Class A shares.
• Class A mutual fund shares typically include substantial upfront sales charges, known as “front-end loads.” They generally are suitable only as long-term investments and not as vehicles for short-term trading because an investor usually must hold A shares for a long period of time to account for the front-end load. Mutual fund “switching” occurs when a customer sells mutual fund shares and reinvests the proceeds in another mutual fund company, often incurring additional charges and commissions.
• In addition, many issuers of front-end load mutual funds offer breakpoint discounts. Generally, an investor can procure a breakpoint discount through a single purchase large enough to reach a breakpoint or, in the alternative, through multiple purchases in either a single mutual fund or mutual fund family. Certain mutual funds also offer breakpoints after “householding” accounts or by aggregating purchases in multiple accounts owned by the customer or persons related to the customer.
• From June 2016 through November 2017, Farmers Financial sold approximately $11.5 million in mutual funds, constituting approximately 20% of the firm’s revenue.
• Although new mutual fund accounts were directly opened with the issuer, the firm required its registered representatives to submit these accounts to firm principals for review and approval.
• Farmers Financial failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws and regulations with respect to its mutual fund business. Specifically, the firm’s primary tools to supervise its mutual fund business—the switch, breakpoint, and bypass reports—failed to constitute a reasonable supervisory system.
• Farmers Financial had insufficient resources and relied on a manual review of the switch, breakpoint, and bypass reports.
• The switch and breakpoint reports included inaccurate or incomplete information and had other data issues that further delayed their review.
• The bypass report consistently included hundreds of transactions per month. For eight months during the relevant period, there were over 300 transactions on each monthly report. and in some cases, the number significantly exceeded that number. In order to follow up on transactions included in the bypass report, the surveillance team undertook an extensive manual review process. This included, among other things, contacting registered representatives, obtaining customer account documents, and tracking the registered representatives’ responses over time.

Accordingly, FINRA concluded that Farmers Financial violated FINRA Rules 3110(a) and 2010.

How to Recover Losses or Obtain a Free Consultation

If you have lost money with Farmers Financial Solutions, LLC, contact securities arbitration lawyers August Iorio and Jorge Altamirano of Iorio Altamirano LLP at august@ia-law.com, jorge@ia-law.com, or toll-free at (646) 330-4624 for a free and confidential evaluation of your account or insurance policy.

Iorio Altamirano LLP is a securities arbitration law firm based in New York, NY. We pursue FINRA arbitration claims nationwide on behalf of investors to recover financial losses arising out of wrongful conduct by financial advisors and brokerage firms.

According to public records, shortly after Mr. Raskin’s termination, a customer complained that Mr. Raskin engaged in unauthorized trading and churning of mutual funds and money funds from January 2018 until January 2020. Peculiarly, Merrill Lynch denied this customer’s complaint.

Investors should be aware that filing a complaint directly with a financial institution, like Merrill Lynch, is not the same as filing a securities arbitration complaint. If an investor is seeking monetary compensation, the investor must initiate a securities arbitration through FINRA Dispute Resolution Services.

Securities arbitration is a unique and complex practice area. Investors should seek out experienced counsel who understands the FINRA forum and can navigate the arbitration process to effectively advocate on their behalf.

If you have suffered financial losses investing with Ryan Raskin or suspect that Mr. Raskin made trades in your account that were not authorized or excessively traded your account, contact New York securities arbitration law firm Iorio Altamirano LLP for a free and confidential review of your account or annuity contract.

Iorio Altamirano LLP represents investors that have disputes with their financial advisors or brokerage firms, such as Merrill Lynch.

FINRA Letter of Acceptance, Waiver, and Consent No. 2020066135901

Ryan Raskin and FINRA entered into a Letter of Acceptance, Waiver, and Consent (“AWC”) on January 13, 2021, after Mr. Raskin refused to provide documents and information in connection with FINRA’s investigation into whether Mr. Raskin made inappropriate investment recommendations involving mutual funds.

On August 31, 2020, in connection with an investigation into the circumstances of Mr. Raskin’s termination from Merrill Lynch, FINRA sent a request to Mr. Raskin to produce documents and information pursuant to FINRA Rule 8210. Mr. Raskin reportedly stated during a phone call and email on September 8, 2020, that he would not provide the requested information or documents at any time. On December 17, 2020, FINRA sent a second request to Mr. Raskin to produce the same documents and information. Mr. Raskin reportedly stated during a phone call on December 17, 2020, that he did not intend to respond to the request.

By refusing to provide the information or documents, Mr. Raskin violated FINRA Rules 8210 and 2010. Accordingly, FINRA barred him from associating with any broker-dealer in all capacities.

Financial Advisor Ryan Ashley Raskin (CRD# 5539610)

Ryan Ashley Raskin had 11 years of experience in the securities industry. He was employed and registered by the following brokerage firms in Beverly Hills, California:

• Morgan Stanley Smith Barney from May 2009 until May 2016.
• Merrill Lynch from May 2016 until March 2020.

Merrill Lynch discharged Mr. Raskin on March 4, 2020. In connection with his termination, Merrill Lynch alleged that Mr. Raskin’s business practices were inconsistent with Merrill Lynch’s standards, including inappropriate investment recommendations involving mutual funds.

A few months later, in September 2020, a customer submitted a complaint to Merrill Lynch about Mr. Raskin’s conduct. The customer alleged that Mr. Raskin engaged in unauthorized trading and churning from January 2018 until January 2020. Mutual funds and money funds were the securities at issue. However, even though the customer’s allegations are remarkably similar to the allegations made by Merrill Lynch when it fired Mr. Raskin a few months earlier, Merrill Lynch denied the customer’s complaint.

According to Mr. Raskin’s BrokerCheck report, this customer did not file a securities arbitration complaint. Investors should be aware that even if a firm such as Merrill Lynch denies their complaint, they can still file a securities arbitration through FINRA Dispute Resolution Services.

In non-discretionary accounts, customers retain discretion, and brokers must always obtain their customer’s permission before placing a trade. You can read more about unauthorized trading in the context of both discretionary and non-discretionary accounts here: Unauthorized Trading.

Excessive trading occurs when a financial advisor makes many trades in a customer’s account, not to benefit the customer but to generate commissions for the broker. Excessive trading is unethical and illegal.

If you or a loved one were a customer of Ryan Raskin and either sustained financial losses or suspect inappropriate trading activity in your investment or retirement account, contact Iorio Altamirano LLP for a free and confidential evaluation.

Merrill Lynch: A Duty to Supervise

Brokerage firms, like Merrill Lynch, must properly supervise financial advisors and customer accounts. Brokerage firms are required to establish and maintain a reasonably designed system to oversee account activity, such as mutual fund switches and the improper use of discretion, to ensure compliance with securities laws and industry regulations. When a brokerage firm fails to supervise its financial advisors or the investment account activity sufficiently, it may be liable for investment losses sustained by customers.

How to Recover Losses or Obtain a Free Consultation

If you have suffered financial losses investing with Ryan Raskin or suspect that Ms. Raskin did not have your best interest in mind when recommending investments or trading in your account, contact New York securities arbitration lawyer August Iorio of Iorio Altamirano LLP at august@ia-law.com or toll-free at (646) 330-4624 for a free and confidential evaluation of your account.

Iorio Altamirano LLP is a securities arbitration law firm based in New York, NY. We pursue FINRA arbitration claims nationwide on behalf of investors to recover financial losses arising out of wrongful conduct by financial advisors and brokerage firms.

Investors who have received partial restitution from Transamerica Financial through FINRA’s order may still be entitled to additional recovery. A FINRA partial restitution order does not preclude investors from pursuing their own claims to seek restitution or other available remedies.

If you have lost money with Transamerica Financial Advisors, Inc., contact New York securities arbitration attorney August Iorio of Iorio Altamirano LLP. Iorio Altamirano LLP represents investors with disputes with their financial advisors or brokerage firms, such as Transamerica Financial Advisors, Inc.

August Iorio can be reached at august@ia-law.com or toll-free at (646) 330-4624 for a free and confidential review of your account.

Transamerica Financial Advisors, Inc.’s Letter of Acceptance, Waiver, and Consent

Transamerica Financial Advisors, Inc. and FINRA entered into a Letter of Acceptance, Waiver, and Consent (“AWC”) on December 21, 2020, over allegations that it failed to reasonably supervise its stockbrokers’ recommendations of three different products – variable annuities, mutual funds, and 529 plans.

Failure to Supervise Variable Annuity Recommendations:

FINRA alleged that from May 1, 2010, through May 15, 2016, Transamerica Financial failed to reasonably supervise representatives’ variable annuity recommendations. Specifically, FINRA alleged that during this period:

• Transamerica Financial sold over 51,000 variable annuity policies.
• Transamerica Financial and its advisors received over $591 million in compensation from new variable annuity sales, trails, and subsequent contributions in the form of gross dealer commissions.
• The firm’s commissions from the sale of variable annuities comprised more than 40% of its total revenue.
• Variable annuities are complex investments that are commonly marketed and sold to retirees or individuals saving for retirement.
• FINRA Rules retire that firms provide more comprehensive and targeted protection to investors who purchase or exchange variable annuities because they are complicated investments.
• When recommending a variable annuity exchange, Transamerica Financial required its financial advisors to complete a six-page disclosure form. The form included important disclosures to the customer related to the fee structure, benefits, and features of both the new and existing variable annuities, as well as the representative’s rationale for recommending the exchange.
• However, Transamerica Financial’s system for supervising variable annuity sales and exchanges was deficient, resulting in various sales practice violations.
• Most significantly, the firm failed to detect that certain of its representatives made thousands of misstatements to customers in recommending variable annuity exchanges, understating the benefits of the existing variable annuity, and overstating the benefits of the new variable annuity.
• Transamerica Financial failed to supervise advisors’ annuity exchange recommendations reasonably:
  • Transamerica Financial relied on the information in the disclosure forms to determine whether to approve variable annuity exchanges.
  • However, Transamerica Financial failed to provide adequate training to its stockbrokers and supervisors. The training did not adequately teach advisors how to complete the disclosure forms. Correspondingly, the firm did not provide sufficient training to supervisors regarding how they should verify the information on the disclosure forms or use that information to conduct a meaningful comparison of the old and new variable annuities.
  • As a result of these supervisory deficiencies, certain firm principals approved variable annuity exchanges based on disclosure forms that contained inaccurate or missing information.
  • Between January 1, 2014, and May 15, 2016, more than half of the 3,781 exchanges approved by the firm contained at least one misstatement or omission.
  • These inaccuracies and omissions, which pertained to surrender charges, fees, and other features of the existing and proposed variable annuities, each had the effect of making the exchange appear to be more favorable than was the actual case.
  • For example, 984 disclosure forms (or 26%) were either blank or stated that there were no advantages associated with retaining the customer’s existing variable annuity.
  • These misstatements or omissions prevented Transamerica Financial’s reviewing principals from having a reasonable basis for approving these transactions.
• Transamerica Financial also failed to surveil advisors’ rates of variable annuity exchanges reasonably.
  • From May 1, 2010, through May 15, 2016, Transamerica Financial maintained an exception report for analyzing variable annuity exchange patterns, but the report was not reasonably designed.
• Transamerica Financial failed to supervise representatives’ variable annuity share-class recommendations reasonably.
  • From May 1, 2010, through May 15, 2016, Transamerica Financial sold variable annuity contracts with different share class options, including B shares, L shares, and C shares.
  • B-share contracts are the most common share class sold in the industry and typically have a seven-year surrender period. L-share contracts typically provide a shorter surrender period of three to five years and have annual fees between 0.35% and 0.50% higher than most B-share contracts. However, some L-share contracts have a specific provision, commonly called a “persistency credit,” which reduces the annual fees, so it is comparable to a B-share contract after the product is held for a period of time, generally seven to ten years. C-share contracts typically have no surrender period and have annual fees that are 0.05% to 0.10% higher than most L-share contracts.
  • Because C- and L-share contracts generally charge higher fees than comparable B-share contracts, the sale of these contracts may raise suitability concerns when sold to customers with long-term investment horizons.
  • This is especially true when combining such contracts with a long-term living benefit rider, such as a Guaranteed Minimum Income Benefit (GMIB) rider or Guaranteed Minimum Withdrawal Benefit (GMWB) rider. These riders typically cost the customer additional annual fees ranging from 1.0% to 1.5% of the variable annuity contract’s face value. GMIB riders usually require a holding period of ten years before the customer can access the income stream benefit. GMWB riders typically require the customer to hold the variable annuity for more than five years to obtain the full benefit of the guaranteed minimum withdrawal.
  • From May 1, 2010, to May 31, 2015, the firm sold 1,965 C-share contracts and 7,809 L-share contracts. These transactions accounted for 21.9% of all variable annuities sold during that period, for an aggregate principal amount of approximately $1.03 billion.
  • The firm’s representatives paired nearly 41% of C shares and 82.5% of L shares with long-term living benefit riders such as a GMIB or GMWB. Moreover, many of Transamerica Financial’s customers who purchased C or L shares had longer-term investment horizons of over seven years.
  • Transamerica Financial did not reasonably supervise the sale of these multi-share class variable annuities.
  • First, Transamerica Financial failed to provide proper training and guidance to its representatives on the features, fees, and surrender charges of the various share classes. As a result, certain representatives lacked the information necessary to compare share classes in making suitability determinations. Similarly, the firm failed to provide adequate training or guidance to its supervisors regarding variable annuity share classes. Consequently, supervisors did not identify common red flags, including sales of C- and L-share contracts to customers with no short-term liquidity needs or to customers who indicated a long-term investment horizon, and representatives who recommended that customers combine a C-share or L-share purchase with a long-term living benefit rider.
  • Second, Transamerica Financial lacked a reasonably designed system to detect red flags of inappropriate share-class recommendations. Transamerica Financial did not have any system to monitor for patterns or trends pertaining to variable annuity share-class suitability. In fact, the firm’s blotter for variable annuity transactions did not capture share-class data.
  • Even when the firm became aware of red flags regarding representatives’ variable annuity share-class recommendations, it failed to take appropriate action.
  • For example, the firm was aware of representatives who employed a “one-size-fits-all” approach with respect to variable annuity share classes recommended to their customers. At least four Transamerica Financial representatives sold the same shorter-term share class to between 70% and 95% of their variable annuity customers.
  • Although Transamerica Financial’s supervisory and compliance personnel were aware of these representatives’ tendency to sell only one share class, the firm did not reasonably supervise these representatives to ensure that they had a reasonable basis for each share class recommendation to their customers.

If you purchased a variable annuity through Transamerica Financial, contact investment advocate law firm Iorio Altamirano LLP for a free and confidential review of your account.

What is a Variable Annuity?

A variable annuity is a contract between an investor and an insurance company, whereby the insurance company promises to make periodic payments to the investor or a beneficiary designated by the investor. A variable annuity serves as an investment account that may grow on a tax-deferred basis, includes insurance features, and offers the investor to receive periodic income payments. Variable annuities allow customers to choose from a complex array of contract features and investment options, including various share classes and optional riders. Each variable annuity is unique. The investor pays extra for the features offered by variable annuities.

Variable annuities can help investors meet retirement or other long-term goals. However, Variable annuities are not suitable for all investors, especially for investors with short-term needs or objectives. Variable annuities are complex and can be costly due to fees or taxes and surrender charges that may apply if money is withdrawn early. Variable annuities also involve investment risks and include contract fees. Accordingly, financial advisors must exercise particular care to ensure that the purchase or exchange of variable annuity is suitable for a customer before recommending the product to a customer.

FINRA Rule 2111 requires that all investment recommendations be in the best interest of the customer. FINRA Rule 2330 provides investors with additional protections related to annuities. The rule requires that when a financial advisor recommends an exchange of a variable annuity, the financial advisor must consider whether the customer would incur a surrender charge, be subject to a new surrender period, lose existing benefits (such as death, living, or other contractual benefits), or be subject to increased fees or charges (such as mortality and expense fees, investment advisor fees, or charges for riders and similar product enhancements).

Failure to Supervise Mutual Fund Sales

FINRA alleged that from January 1, 2009, through November 15, 2016, Transamerica Financial failed to supervise financial advisors’ sale of certain mutual funds reasonably. Specifically, FINRA alleged that during this period:

• Transamerica Financial sold mutual funds with different share classes, including A shares, B shares, and C shares.
• Class A shares typically include a front-end sales charge and have annual fund expenses, including ongoing distribution and service fees typically around 0.25%.
• Class B and C shares do not generally carry a front-end sales charge but have significantly higher distribution and service fees (typically 1%) and may include a contingent deferred sales charge.
• During this period, many mutual funds waived the front-end sales charges on A shares for certain retirement plans and charitable organization customers.
• Transamerica Financial failed to supervise the application of these sales charge waivers reasonably.
• The firm relied on its representatives to determine the applicability of sales charge waivers but failed to provide adequate guidance or training to assist them in making this determination.
• The firm relied on its financial advisors to determine the applicability of sales charge waivers to customers’ mutual fund purchases, but the firm failed to provide guidance to representatives to assist them in making this determination.
• Furthermore, Transamerica Financial failed to establish a system to verify whether waivers were applied correctly.
• As a result, Transamerica Financial failed to apply approximately $438,239 in available waivers to customers in 433 accounts.

If you purchased a mutual fund through Transamerica Financial, contact securities arbitration law firm Iorio Altamirano LLP for a free and confidential evaluation of your account.

Failure to Supervise 529 Savings Plans Recommendations

FINRA alleged that from May 1, 2010, through May 31, 2015, Transamerica Financial failed to reasonably supervise brokers’ recommendations to customers to purchase certain share classes of 529 saving plans. Specifically, FINRA alleged that during this period:

• 529 plans are tax-advantaged municipal securities designed to encourage saving for the future educational expenses of a designated beneficiary.
• Shares of 529 plans are sold in different classes with different fee structures. Class A shares typically impose a front-end sales charge but charge lower annual fees compared to other classes.
• Class C shares typically impose no front-end sales charge but impose higher annual fees than Class A shares.
• Because of their higher annual fees, Class C shares may be more expensive over extended holding periods. Consequently, Class A shares are frequently the suitable option for accounts with younger beneficiaries and a longer investment horizon.
• Because 529 plans are municipal securities, the sale of 529 plans is governed by the Municipal Securities Rulemaking Board (MSRB). MSRB Rule G-27(a) requires each broker, dealer, and municipal securities dealer to supervise the conduct of its municipal securities activities to ensure compliance with MSRB rules and federal securities laws. MSRB Rules G-27(b) and (c) require each firm to establish and maintain a system, and to establish, maintain, and enforce written procedures, to supervise its municipal securities activities in a manner that is reasonably designed to achieve compliance with the federal securities laws and MSRB Rules
• Transamerica Financial did not provide adequate guidance to representatives regarding the importance of considering share-class differences when recommending 529 plans and did not provide supervisors with the information necessary to evaluate the suitability of 529 share-class recommendations properly.
• For example, the firm’s policies and procedures relating to 529 plans did not instruct supervisors to consider either (1) the beneficiary’s age or (2) the number of years until expected withdrawals—both critical factors in determining the suitability of the recommended share class.

If a Transamerica financial advisor sold you a 529 Savings Plan, contact investor protection law firm Iorio Altamirano LLP for a free and confidential review of your account.

Transamerica Financial Advisors, Inc.– A Duty to Supervise

Brokerage firms like Transamerica Financial Advisors, Inc. must supervise financial advisors and customer accounts properly. Brokerage firms must also establish and maintain a reasonably designed system to oversee account activity, such as excessive trading, to ensure compliance with securities laws and industry regulations. When a brokerage firm fails to supervise their financial advisors or the investment account activity sufficiently, they may be liable for investment losses sustained by customers.

Investment Loss Recovery

A FINRA partial restitution order does not preclude investors from pursuing their own claims to seek restitution or other available remedies.

If you have lost money with Transamerica Financial Advisors, Inc., contact securities arbitration attorney August Iorio of Iorio Altamirano LLP.

August Iorio can be reached at august@ia-law.com or toll-free at (646) 330-4624 for a free and confidential evaluation of your account.

Iorio Altamirano LLP is a securities arbitration law firm based in New York, NY. Iorio Altamirano LLP pursues FINRA arbitration claims nationwide on behalf of investors to recover financial losses arising out of wrongful conduct by stockbrokers and brokerage firms.