Securities

Churning

Churning is the illegal practice of excessive trading in a customer's account by a broker primarily to generate commissions, without regard to the customer's investment objectives.

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Exam Tip

Churning = excessive trading for commissions. Requires: control + excessive trading + intent. Turnover ratio > 6x = red flag.

What is Churning?

Churning occurs when a broker engages in excessive trading in a customer's account to generate commissions rather than to benefit the customer. It's a form of securities fraud that violates FINRA rules and fiduciary duties.

Elements of Churning

To prove churning, three elements must be present:

ElementDescription
ControlBroker had control over the account
Excessive TradingTrading was excessive given account objectives
IntentBroker acted for personal gain, not client benefit

Measuring Excessive Trading

MetricDescriptionPotential Red Flag
Turnover RatioAnnual trading volume ÷ Account value> 6x may indicate churning
Cost-to-Equity RatioTrading costs ÷ Account value> 20% annually
In-and-Out TradingQuick purchase and sale of same securityFrequent occurrences

Turnover Ratio Example

FactorAmount
Account Value$100,000
Annual Purchases$600,000
Turnover Ratio6x (potentially excessive)

Warning Signs of Churning

  • Frequent trading without clear strategy
  • High commission costs relative to account size
  • Trades that don't match your objectives
  • Broker discouraging long-term holdings
  • Unauthorized trades
  • Large positions held briefly

Who is at Risk?

Risk FactorWhy
Discretionary AccountsBroker can trade without approval
Unsophisticated InvestorsMay not recognize excessive trading
Elderly ClientsMay be more trusting, less monitoring
Commission-Based AccountsBroker incentive to trade more

Regulatory Violations

RuleViolation
FINRA Rule 2111Suitability - recommendations must be suitable
FINRA Rule 2010Standards of Commercial Honor
Securities Exchange ActFraud and manipulation provisions
State Blue Sky LawsFraudulent practices

Defenses Against Churning

DefenseExplanation
Client SophisticationClient understood and approved trades
Investment StrategyTrading consistent with stated objectives
Client DirectionClient requested the trades
No ControlBroker didn't control the account

Remedies for Churning Victims

  • FINRA arbitration
  • SEC complaint
  • State securities regulator complaint
  • Civil lawsuit
  • Recovery of commissions and losses

Exam Alert

Churning requires: (1) control, (2) excessive trading, and (3) intent to generate commissions. Turnover ratio above 6x may indicate churning. Know this is a FINRA Rule 2111 suitability violation!

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