The Reading — demonstration account · computed by the same analysis engine the live page runs, from the bundled demonstration file (sample.csv). The counsel-side companion is the fabricated mock report.
All transactions in this file are within the six-year FINRA arbitration window.
Next to fall outside it: 2030-01-08 — 1222 days from today.
This is the deadline for one forum — FINRA arbitration — and nothing else. The deadline that actually ends a claim comes from state law, is often shorter, and depends on facts this file does not contain, including when you could reasonably have discovered the problem. Nothing here should be read as saying you still have time, or that you do not. It is a reason to ask someone quickly, not an answer.
No claim is eligible for submission to arbitration where six years have elapsed from the occurrence or event giving rise to the claim. Rule 12206(c) states the rule does not extend applicable statutes of limitations. Rule 12206(b) provides that dismissal under the rule does not prohibit a party from pursuing the claim in court.
What it does not settle. This is an eligibility rule for one forum, not a statute of limitations. The deadline that actually bars a claim is set by state law, varies by state and by the legal theory, is often shorter than six years, and cannot be determined from a transaction file. Only a lawyer in the relevant state can tell you what it is.
19 trades over 7 months — about 3 a month. $942,740 bought against $806,020 sold. Money bought and sold in the same window is money that never had time to do anything.
9 trade(s) over 5 month(s); $297,527 bought, $455,698 sold.
Annualized turnover ≈ 7.1× (total purchases $1,240,267 against an average net-invested balance of ≈$180,764 over 354 days). Computed from trade flows only — statement balances would refine this.
A series of recommended transactions may be unsuitable when taken together, even where each transaction viewed in isolation would be suitable. Excessive turnover, excessive cost-to-equity ratio and in-and-out trading are the factors named.
Limits: The rule names no numeric threshold. Any specific turnover figure is a rule of thumb from case law, not a line drawn by the regulator.
read it ↗Applied the "well-managed account" measure to a churning claim and discussed annualized turnover as evidence of excessive trading.
Limits: A 1981 appellate decision applying its own facts. Courts differ; turnover alone has never been dispositive.
read it ↗A broker-dealer must have a reasonable basis to believe that a series of recommended transactions is not excessive and is in the retail customer’s best interest when taken together.
Limits: Applies to broker-dealers and to recommendations made on or after June 30, 2020.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at FINRA Regulatory Notice 18-13, Quantitative Suitability (Apr. 20, 2018), at 3
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at Rafael Pinchas, 54 S.E.C. 331, 339-40 (1999), Exchange Act Release No. 41816 (Sept. 1, 1999)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at Mihara v. Dean Witter & Co., 619 F.2d 814, 821 (9th Cir. 1980)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at Arceneaux v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 767 F.2d 1498, 1502 (11th Cir. 1985)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at Daniel Richard Howard, Exchange Act Release No. 46269 (July 26, 2002)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of roughly six that regulators describe at Jack H. Stein, 56 S.E.C. 108 (2003), Exchange Act Release No. 47335 (Feb. 10, 2003)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of 3.21 that regulators describe at Richard G. Cody, Exchange Act Release No. 64565 (May 27, 2011), aff’d sub nom. Cody v. SEC, 693 F.3d 251 (1st Cir. 2012)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗a turnover of 7.07 exceeds the guidepost of 2.10 that regulators describe at Sandra K. Simpson, 55 S.E.C. 766, 794 (2002), Exchange Act Release No. 45923 (May 14, 2002)
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗A factual note on the rule text: effective June 30, 2020, FINRA Rule 2111.05(c) no longer contains the control element it previously carried; FINRA Regulatory Notice 20-18 (June 19, 2020) records the deletion. Conduct before that date is measured against the earlier rule text, which included it.
Limits: A published guidepost, quoted from the cited source and verified against it on 2026-08-02. It describes what regulators and courts have said about these ratios in general; it establishes nothing about this account on its own.
read it ↗14 completed round-trip lots; median holding period 14.5 days; 13 lots (93%) held ≤30 days.
In-and-out trading — selling a position and buying back a similar one shortly after — is named as an indicator of quantitative unsuitability.
Limits: Short holding periods are not misconduct by themselves; an account may be intended for active trading.
read it ↗$138.60 of explicit fees/commissions across 28 trades. Advisory fees billed outside trade confirms are not visible in trade files.
Total annual costs divided by average equity gives the return an account must earn simply to break even. It is a standard measure in excessive-trading analyses.
Limits: A high figure invites a question; fees can be reasonable for an account that requires active management.
read it ↗Recent SEC administrative proceedings against investment firms — the Commission’s current enforcement docket, not cases matched to these facts.
| Date | Respondent | Release |
|---|---|---|
| Aug. 28, 2026 | Alpine 4 Holdings, Inc. (f/k/a Alpine 4 Technologies, Inc.) | 34-106212 |
| Aug. 21, 2026 | R4 Capital Funding LLC | 34-106171 |
| Aug. 14, 2026 | GlennCap LLC and Jonathan Vincent Glenn | 34-106135 |
| Aug. 12, 2026 | Investmark Advisory Group LLC | 34-106124 |
| Aug. 12, 2026 | Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC | 34-106123 |
| Aug. 12, 2026 | Wedbush Securities, Inc. | 34-106122 |
Nothing here is advice about whether any claim exists. It is the set of doors, what each one can and cannot do, and the records that decide these cases.
Their disclosures say "member FINRA/SIPC", or you found them on BrokerCheck. Account paperwork usually says "brokerage account".
Can Runs the arbitration forum where customer claims against brokerages are actually heard, and takes complaints that feed its own examinations.
Cannot FINRA does not get your money back on a complaint. A complaint is not a claim — recovery comes from arbitration, which is a separate filing with its own clock.
File a complaint · BrokerCheck — look the firm and person up · How arbitration works
They gave you a "Form ADV Part 2A brochure", charge a percentage fee rather than commissions, and appear on the SEC adviser search.
Can Takes tips, complaints and referrals; brings enforcement actions under Section 206; can order disgorgement and bar individuals from the industry.
Cannot The SEC acts for the public, not for you. It will not represent you, usually will not tell you what it did with your tip, and cannot award you damages.
Submit a tip, complaint or referral (TCR) · Adviser search — Form ADV and disciplinary history · Office of the Investor Advocate
Smaller local firms are usually registered with the state securities regulator rather than the SEC. The adviser search page shows which.
Can Registers and examines smaller advisers, investigates complaints, and in many states has restitution powers the SEC does not use for individuals.
Cannot Powers and appetite vary widely by state.
Look the firm up first — the adviser and BrokerCheck searches above will tell you which kind of firm it is, and that determines everything else. A firm can be both, registered as a brokerage and as an adviser, in which case which hat they wore for your account is itself a question.
People read "the adviser broke a federal fiduciary duty" and assume a federal lawsuit follows. It usually does not. The SEC can act on Section 206; a private client generally cannot sue for damages under it. Claims normally proceed as state-law fiduciary or contract claims, or — if the firm is a brokerage — in FINRA arbitration.
Transamerica Mortgage Advisors, Inc. v. Lewis, 444 U.S. 11 (1979) — There is no private right of action for damages under Section 206 of the Investment Advisers Act. Section 215 implies only a limited remedy — rescission of the advisory contract, an injunction against its continued operation, and restitution of what was paid under it.
What it does not settle. This concerns the federal Advisers Act only. It says nothing about state-law claims for breach of fiduciary duty, negligence, or breach of contract, which is where these cases are normally brought, nor about FINRA arbitration against a brokerage.
Keep everything exactly as it is. Do not delete emails or close the account to "make a clean break" — the records held by the firm are evidence, and closing an account can make some of them harder to obtain.
Most lawyers who take these cases work on contingency — a share of what is recovered rather than a fee up front — and consultations are usually free. Being told a case is too small is common and is not a judgment about whether you were wronged; it is about the cost of pursuing it.
SAMPLE — fabricated entities: the demonstration account, its owner, and every trade above are invented; no adviser, firm, or client is named or implied, and none exists. The tickers refer to ordinary, widely held securities; any resemblance to a real account or person is coincidental. This page renders offline, loads no external resources, and sends nothing anywhere.