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ONLINE BROKER-DEALER MARGIN PRACTICES:
GODOT CALLED, SAID HE’LL BE RIGHT BACK, PLEASE HOLD

by Bill Singer, Esq.

The Friday Crash

It’s the week following the Friday, April 14, 2000 stock market crash and my phone’s ringing off the hook with disgruntled public investors looking for an attorney to sue their broker-dealer. The Internet is claiming more victims, but it’s not the usual suspects. Oddly I’m not hearing as many complaints as I usually do about specific Internet stocks or unauthorized trading. No, this time there’s something markedly different, the customers are complaining about their online broker-dealers’ frustrating margin practices.

The Monday Night Message

Here’s a fairly typical story. On the Monday evening following the Friday crash, a customer of a major online broker-dealer arrives home and listens to a message on his home answering machine.

Hello, this is Joe Smith from XYZ Online Broker-Dealer. I need to speak to you immediately about your account. Please call me at 1-800-123-4567.

Now the customer isn’t stupid and guesses that the value of his account may have dropped to a level where additional maintenance margin is required. Having quickly done the computation, he expects to be asked to deposit an additional $5,000.00. In his portfolio at XYZ Online are stocks A, B, and C. Our hypothetical client also has $100,000 in a checking account from which he can wire funds to his brokerage account.

Tuesday

So Tuesday morning, first thing after arriving at his desk at work, our customer calls 1-800-123-4567 and hears the following message:

Thank you for calling XYZ Online. All customer service representatives are presently busy. Please stay on the line and the next available operator will take your call.

Five minutes become ten and ten become fifteen and so on. After two or three attempts to reach Mr. Joe Smith at XYZ, the customer gives up and assumes that if it’s really urgent Mr. Smith will find a way to reach him during the day at work --- by office e-mail or office telephone. The customer remembers that when he filled out his new account forms he was asked to provide both day and evening and both office and home: telephone numbers, cellular telephone numbers, facsimile telephone numbers, and e-mail addresses. Upon arriving home on Tuesday evening the customer finds no more answering machine messages from XYZ, no mail, no home e-mail, and no overnight courier packages.

Wednesday

Still concerned about the Monday-night message, our intrepid customer once again attempts to telephone XYZ on Wednesday. Alas, after several forays he is again rebuffed by XYZ’s apparently understaffed back-office. The thought now occurs to him that maybe Mr. John Smith has an e-mail address. So the customer logs on to the broker-dealer’s website. Hmmm . . . there’s no disclosure of any phone numbers or e-mail addresses for customer service on the home page. So the customer starts clicking and clicking, trying to find Mr. Smith or even a direct line to the margin department. Odd, there just isn’t any apparent, simple, direct way to get there from here. Finally, listed under some relatively obscure link is the very same 800 number he’s been dialing without success for two days.


That’s no help. After a few more exploratory clicks our customer finds a somewhat ominous e-mail link. [1] By this time, having reached the frustration point-of-no-return, our customer simply throws caution to the wind and transmits an e-mail message from a non-secure page to a general customer-service mailbox. He identifies his account number, gives his office daytime telephone number and office e-mail address, and urges XYZ or the elusive Mr. Smith to contact him concerning Monday night’s message.

Thursday

On Thursday the customer half-heartedly attempts to reach customer service by telephone, but after a few more fifteen-plus minute taped telephone messages asking him to hold he returns to work. What will prove to be a misplaced sense of security envelops our protagonist. Since Monday’s telephone message, no one from XYZ has followed up. The market has recovered quite a bit since Friday and the customer’s portfolio is in better shape. Whatever Mr. Smith apparently needed to speak to him about is likely not a major issue.

But Thursday night brings a shock. Upon arriving home there is a letter from XYZ dated Monday, postmarked Tuesday, telling the customer that if he hasn’t deposited $8,235 in his account by Wednesday that XYZ will be forced to sell out securities to cover the debit. The customer is aghast! Today’s Thursday! They sent me a letter that arrives on Thursday warning me to deposit additional funds by yesterday? Are they crazy!

Friday

Friday morning, fully enraged and determined to speak to someone, the customer holds on for nearly one-half hour. Finally a human being picks up. Our customer relays the entire saga and the customer service representative advises that he doesn’t see anything on his screen indicating any problem, but Mr. Smith is in the Margin Department, not Customer Service, so maybe they have some issues with the account. The service representative then indicates that she will transfer the customer to Mr. Smith. The customer, worried about getting disconnected by accident, intelligently asks for the direct telephone number for Mr. Smith. I’m sorry sir but we’re not permitted to give that information out. Next, the customer asks for the direct telephone number for the Margin Department. That’s 1-800-123-4567. Half puzzled and half dismayed, the customer points out that it’s the same 800 number as customer service. The representative confirms the observation. Seems that all outside inquiries must come through this same number. Fed up with the apparent stupidity of the process, the customer submits to the nightmare and requests that his call be forwarded to Mr. Smith. After a few seconds the transferred call begins ringing.

Hello, this is John Smith; I’m either on the telephone or away from my desk. At the tone please leave a message and I'll get back to you. Thank you.


Insult Added to Injury

During the next several business days the customer receives a confirmation indicating his account was sold out on the Monday following the Friday market crash. His frustration is now transformed into outrage. The written demand for additional funds came three days after the sell-out. They sold out all of his holdings in company C to cover the debit. He didn’t want to sell shares in C; now he has to pay tax on the capital gains. Worse, C recovered to a point where it is now trading above where it was on the day of the sell-out. Further, the customer was ready, willing, and able to wire the necessary funds from his checking account. And to add insult to injury, he still hasn’t heard back from Mr. Smith and no one has responded to his e-mail. Eventually he gets an e-mail back from XYZ.

Thank you for contacting XYZ. We have received your e-mail and someone from customer service will respond to you shortly.

Now the customer starts crunching some numbers and realizes that his margin maintenance debit should only have been about $4,000. He simply cannot figure out where the additional $4,235 in debit came from. Once again he telephones XYZ and also sends another e-mail, hoping someone will respond with a pointed explanation. After holding on for nearly 20 minutes, he reaches a customer service representative.

The customer now learns, for the first time, that XYZ had placed the shares of company B on a list requiring 75% margin maintenance and that this increase generated the additional margin call. The customer service representative then offers a very tortured explanation:

Company B was on 30% margin maintenance up until Monday. Following Friday’s crash we decided that Company B was very volatile and decided to add it to our enhanced maintenance margin list. So on Wednesday we physically added Company B to the online enhanced maintenance margin list. But even though it wasn’t publicly disclosed until Wednesday, we have the right to increase the maintenance margin on any stock at our sole discretion. That’s why we sent you Monday’s letter asking for the additional $4,234 for Company B in addition to the $4,000 additional margin for Company A.

The customer is now furious. Why the hell didn’t you sell-out Company B? I would have preferred to eliminate that holding from my portfolio since it now carries a 75% maintenance requirement. The response from customer service was predictable. Well, we tried to speak with you on Monday and we mailed you a letter that same day. And then it goes from bad to worse. The customer futilely notes that XYZ called him at home when he was at work, that when he tried to reach someone to discuss the problem with there was no way to get through, that no one had even substantively responded to his e-mail, and that the so-called Monday letter wasn’t postmarked until the following day and didn’t reach him until Thursday.

I’m sorry, sir. We value your business but if you review your new account forms and margin agreement you will see that we have the discretion to sell out your account without any prior notification.

Yes, the Language is There

And thus we have the genesis for what may be a class-action lawsuit or the initiation of state and federal consumer fraud investigations. It is critical for attorneys representing online brokerages to fully appreciate and to thoughtfully consider the significant policy issues involved in the above amalgam of many real customer complaints, and to make recommendations calculated to reduce litigation exposure and regulatory issues.

A fairly standard margin clause in new account agreements advises public customers that the broker-dealer has the right to require payment upon demand of any debit balance. Further, such provisions empower the broker-dealer with sole discretion to determine whether additional collateral will be required beyond the maintenance margin standards promulgated by the self-regulatory organizations. Perhaps the key discretionary power of the broker-dealer is its ability to sell securities and other property held in a customer’s account without prior notice or demand to the account holder.

Consequently, as a matter of legal precedent and industry custom and practice, broker-dealers operate with virtual impunity when they deem themselves insecure from the financial circumstances arising in a margin account. However, the above facts related in the customer’s odyssey might be misunderstood by the industry as sounding solely in margin lore. I believe equally legitimate perspectives (and those likely to be espoused by the plaintiff’s bar) are those of breach of contract, fiduciary breach, fraud, recklessness, negligence, and the governmental/regulatory issues traditionally raised in consumer fraud investigations.

The AOL Settlement

In a classic example of becoming a victim of one’s own success, AOL, the world’s largest online service, decided in late 1996 to replace its hourly charges with a flat monthly fee. As a consequence, during December 1996 and January 1997 the company enrolled unprecedented numbers of new users, who effectively overwhelmed the system’s capacity and prevented other subscribers from either logging on or doing so in a reasonably timely manner.

As a consequence of the bottleneck, AOL was named in several class-action lawsuits alleging fraudulent and malicious representation, breach of contract, unjust enrichment, deceptive trade practices and false advertising. Similarly, numerous state attorneys general initiated investigations in response to consumer complaints. Subsequently, AOL reached a four-part agreement with the attorneys general to refund up to $39.90 to customers who had difficulty connecting online during December/January. AOL settled with the attorneys general by agreeing to pay refunds to customers who had difficulty connecting online, to implement system enhancements to improve access, to temporarily cease advertising, to hire more operators, to permit account cancellation by mail or facsimile, and to prominently disclose such cancellation information online.

NYS Attorney General’s Online Brokerage Report

On November 22, 1999, the Office of the New York State Attorney General, the Investor Protection and Securities Bureau and the Internet Bureau, published From Wall Street to Web Street: A Report on the Problems and Promise of the Online Brokerage Industry. In pertinent part, the NYSAG Report stated:

Our review of the customer service records of a number of online brokerage firms confirmed that customers were unable to reach customer service support at these firms earlier this year. This was especially true during times of high volume and volatility . . .

The extent of deficiencies in customer support services is apparent from a review of the average time in which firms answered a customer call (“average response time”), and the rate at which customers simply abandoned unanswered calls. For example:

  • An analysis of key telephone statistics conducted by one firm it was revealed that the total calls answered within 60 and 120 seconds had dropped from almost 100% for both, to one-quarter and one-third respectively, in late January 1999. Additionally, average response time climbed to around 10 minutes in late January 1999, peaking at about 13 minutes in the first half of February . . .

  • At the same firm, the number of abandoned calls also increased. Almost half of all customer calls were abandoned during the period from mid-January to mid-February. Even more striking, on one day in the Spring of 1999, the number of total calls abandoned exceeded the number of calls answered by almost one-third. . . .

  • E-Mail response time also encountered increased backlog. At one firm, the average E-mail response time in hours grew from a low of 14 hours at the end of December 1998, to a high of 90 hours at the beginning of January 1999. In fact, at one point E-mails had exponentially increased at this firm so quickly that despite utilizing overtime customer service personnel to reduce the backlog, there were still thousands in queue awaiting a response.

[I]t is also worth noting that customer service problems experienced by at least one firm were related to obtaining approval from the NASD to hire additional registered securities representatives. NASD Regulation frequently places caps upon a broker-dealer’s employment of registered agents through its member review process . . . [2]

NASD Sanctions E*TRADE

In a similar vein, the NASD announced on May 2, 2000 that it censured and fined E*TRADE Securities, Inc. $20,000 for failing to promptly respond to NASD Regulation (NASDR) requests for information relating to customer complaints. E*TRADE neither admitted nor denied NASDR’s allegations. In a three-month period, from April 1999 to June 1999, NASDR made 17 separate requests for information relating to customer complaints that it had received about the firm, and in each instance E*TRADE failed to provide further information or respond in a timely fashion. According to the NASD’s press release on the settlement, E*TRADE apparently conceded that one result of its 550% account growth from third quarter 1997 to third quarter 1999 has been the “challenge of handling the needs and requests of such a large number of customers.” Barry R. Goldsmith, NASDR Executive Vice President of Enforcement stated that the "prompt response to regulators’ inquiries about customer complaints has to be front and center for all firms. Brokerage firms need to devote the resources that are necessary to handle all aspects of their securities business." [3].

Unanticipated trading volume and account growth have overwhelmed many online broker-dealers’ ability to manage the resulting flow of customer-generated inquiries. Worse, the problem is apparently so severe that it interferes with the online firm’s ability to timely respond to its regulator’s demands. [4] The most compelling solution, i.e., limit the numbers of new accounts based upon a staffing versus accounts formula, is not acceptable within the context of a free-market, capitalist economy. Further, it raises antitrust issues as to restraint of trade or economic barriers to entry into a business. However, at some point the industry must adopt some self-imposed limits requiring minimal capacity capabilities. Otherwise we’re building stadiums for 50,000 fans and selling tickets for 200,000.

Have We Built an Attractive Nuisance?

Online broker-dealers expend huge sums to attract online customers. An online customer, by definition, is one using a computer, using a computer interface, and trading online. Nothing profound, but perhaps more subtle than it appears. The entire marketing thrust is to promote online trading. Of course customers often have the alternative of telephoning a human registered representative, but frequently such transactions come at a higher commission rate (to the customer) and involve lower profit margins (for the broker-dealer).

The invitation from the online broker-dealer is to enter its point-and-click world. Clearly, from the initial point of contact, it is the online experience that is being sold to the consumer. Easier and faster online access. Trade by mouse. Click and the trade is done. Access research online. But markedly absent from the advertising and marketing is a straightforward and simple warning: If you have any problem, we kick you into a parallel universe of telephone calls and snail mail.

Should online broker-dealers contact their online clients concerning urgent margin issues solely by daytime telephone calls to the clients’ homes?

Think about the problem. The typical online client is most likely trading during the day from a work location. So a telephone message to a home telephone number is not exactly calculated to reach the customer on a real-time basis. There has been much speculation that this is a cynically calculated approach designed to give the impression that the broker-dealer really tried to contact the customer. In fact, some suspect that the main purpose of contacting the customer at home during the daytime is to specifically avoid any person-to-person contact, thereby giving the broker-dealer the ability to justify its often-arbitrary decisions concerning sell-outs.

If there has been an unsuccessful attempt to reach a client at home, shouldn’t there be a follow-up effort to the office telephone number and then by e-mail?

Virtually all new account forms seek daytime and evening, home and office telephone numbers. Armed with that information, shouldn’t Margin Departments make at least a reasonable effort to timely communicate with customers in a manner calculated to be effective? Isn’t it fair for a customer to expect that if he is asked for, and provides, a daytime number, his broker will use it? Similarly, why do so many customers complain that margin maintenance demands were not communicated to them by e-mail --- where they would have timely received the information and been able to promptly respond?

In short, why do firms accumulate a database if they don’t intend to use it? A broker-dealer that does not want to utilize its limited personnel to make multiple calls and e-mails can ask clients to select a preferred method of daytime communication.

If an effort to reach customers at their home telephone numbers is unsuccessful, and if decisions are going to be made to sell out accounts within 24-48 hours, what is the point of sending a first-class letter or mailgram that will reach the investor after the sell-out has been consummated?

All attorneys, including this author, are well versed in the art of CYA. However, practitioners need to counsel their clients as to the consequences of such maneuvers. In our customer’s saga, not only was the belated mail notice ineffective, but it may have exacerbated the situation to the point of instigating litigation. Keep in mind that in the hypothetical matter presented above, the mail arrived three-days after the sell-out occurred and one-day after the due date for the customer’s deposit.

Online Margin Departments must better consider the purpose of leaving answering machine messages and sending snail mail correspondence. If such efforts are intended to notify the customer of the potential for a sell-out, they are ineffective and pointless. If the purpose of telephonic and mail notices is to provide the client with an opportunity to select which securities to liquidate or to wire funds, the online broker-dealer knows or should know that the so-called opportunity is illusory. What good is it to leave a return telephone number when it’s virtually impossible for the customer to reach anyone? What value is there in asking a customer to contact the broker-dealer concerning urgent margin matters when the firm knows, or should know, that it is unable to timely answer such calls? And why send warnings by mail that cannot possibly arrive (and may not even be postmarked) until after a sell-out occurs?

For much of the modern era of Wall Street, the standard response to the issues posed in this article has been it doesn’t matter, we don’t even have to give them notice! I submit that such an attitude, while arguably legally correct in significant aspects, may ultimately prove to be dangerous. Admittedly, margin rules and regulations are largely in place for the protection of broker-dealers in order to ensure some financial stability within the marketplace. In light of the recent phenomenon of volatile markets driven by heretofore-unknown online trading forces, broker-dealers must retain the flexibility to increase margin requirements or sell-out positions pursuant to their sole discretion and without notice. However, inherent with such dramatic powers are obligations to educate consumers as to the ramifications of such discretion and the reserved right to act without warning.

In a speech given before the Securities Industry Association earlier this year, NASDR President Mary Schapiro stated:

There are fundamental issues that must be explained to investors regarding margin, for example:

  • Customers must be made aware that the firm can force the sale of securities in a customer’s account if the equity in the account falls below the maintenance margin requirements under the law or under the firm’s higher house requirements.

  • Customers must understand that they remain accountable for any short fall in the account after a margin caused liquidation.

  • Investors must be made aware that the firm can sell their securities without contacting them. I guarantee you that many investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities in their accounts to meet the call unless the customer approves the transaction. [5]


POSTSCRIPT TO MAY 2000 VERSION OF THIS ARTICLE

Proposed NASD Rule 2341

On September 5, 2000, the NASD submitted a proposed rule change to the SEC seeking to add new Rule 2341: Margin Disclosure Statement (“2341 Proposal”), which would require:

[M]embers to deliver to non-institutional customer, prior to or at the opening of a margin account, a specified disclosure statement that discusses the operation of margin accounts and the risks associated with trading on margin. The proposed rule change also would require members to deliver the disclosure statement annually to all non-institutional customers with margin accounts. [6]

The Envelope Stuffer

The 2341 Proposal will require the use of the following language or an alternative substantially similar:

Your brokerage firm is furnishing this document to you to provide some basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts

When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities in your account, in order to maintain the required equity in the account.

It is important that you fully understand the risks involved in trading securities on margin.

These risks include the following:

  • You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities in your account.

  • The firm can force the sale of securities in your account. If the equity in your account falls below the maintenance margin requirements under the law, or the firm’s higher “house” requirements, the firm can sell the securities in your account to cover the margin deficiency. You also will be responsible for any shortfall in the account after such a sale.

  • The firm can sell your securities without contacting you. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.

  • You are not entitled to choose which security in your margin account is liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.

  • The firm can increase its “house” maintenance margin requirements at any time and is not required to provide you with advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account.

  • You are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.

The GAO On-Line Trading Report

In supporting the 2341 Proposal, the “Background” section details a number of concerns emanating largely from customer inquiries and complaints to regulators. Further, in citing the General Accounting Office’s recent on-line trading report, the NASD specifically buttressed the need for the new rule by noting that the

lack of disclosures relating to when firms would sell securities in a margin account to cover margin loans was among the leading margin-related complaints that the SEC received . . .
The GAO Report concluded that better investor protection information, including information relating to margin requirements, was needed on web sites of some on-line broker/dealers. [7]

Four Areas of Concern

More pointedly for this article, NASD identified four specific areas of concern pertaining to margin trading by public customers. In sum and substance, the NASD determined that customers were confused about
  • Margin Calls- Notification: The “mistaken belief that their broker/dealer must contact them for a margin call to be valid . . .”
  • Extensions of time on margin calls: “Some investors believe they are automatically entitled to an extension of time to meet margin calls.”
  • Right to dictate which security is liquidated: “Some investors believe that they have the right to control which securities are liquidated . . .”
  • Members raising their maintenance margin requirements: “Some investors believe that a member must provide thirty days written notice before implementing this type of change.” [8] The Securities Industry Commentator™© 2000 Bill Singer

I would like to thank Lois Yurow, Managing Editor of Wallstreetlawyer.com, for her valuable editing of a version of this article that appeared in Volume 4, Number 1 of the Wallstreetlawyer.com (June 2000)


[1] Commonly, access to an online brokerage account is at least a multi-phase process. A user starts at a non-secure public page, clicks on a link to connect to a secure page, and provides a password and account identification number to gain access to the secure transactional pages. During periods of market volatility, many customers encounter delays in logging on to the secure part of the broker-dealer’s web site. These delays affect trading, but also may make it impossible to send secure e-mails to Customer Service. Of course, customers can send e-mail from their own secure mail programs, but if they cannot obtain the broker-dealer’s e-mail address from the public portion of the web site, they may be limited to using a generic “Contact Us” e-mail screen.

[2] Office of New York State Attorney General Eliot Spitzer, From Wall Street to Web Street: A Report on the Problems and Promise of the Online Brokerage Industry [Section IV. Initial Bumps in the Road: Moving Trading Online: C. Identified Deficiencies in Online Information Systems’ Capacity and Reliability: 6. Customer Support Services], Nov. 22, 1999 at pages 109-110. http://www.oag.state.ny.us./investors/1999_online_brokers/full.pdf

[3] NASDR Press Release, May 2, 2000, http://www.nasdaqnews.com/news/pr2000/ne_section00_108.html

[4] As a frequent critic of securities industry regulators I will be the first to concede that not only are many regulatory requests excessive and unreasonably burdensome, but frequently they come with unrealistic production timeframes. Moreover, the NYSAG Report raises a legitimate concern as to NASDR’s role in hampering its members’ ability to respond to customer and regulator inquiries when it notes that the NASDR’s administrative process delayed one broker-dealer’s efforts to timely employ additional registered personnel.

The NASDR utilizes a frequently criticized and cumbersome system by which members must request modification of existing restriction agreements, i.e., limitations upon the business areas in which a member may engage and upon the numbers of personnel, offices, etc. This system frequently takes weeks and months to approve requests for expansion. Although the purpose and justification for such regulatory reviews is understandable, the timeframes for processing most requests are not. When practitioners inquire as to the reason for delays, the most common response from the Staff is that they are overwhelmed with applications and understaffed. One is compelled to consider NASDR EVP Goldsmith’s statement admonishing the industry “to devote the resources that are necessary to handle all aspects of their securities business.” Perhaps the NASDR should re-evaluate its own staffing levels and allocation of resources.

[5] Opening Remarks by Mary L. Schapiro, 2000 Spring Securities Conference (April 26, 2000),http://www.nasdr.com/1420/schapiro_16.htm

[6] File No. SR-NASD-00-55: Delivery of a Margin Disclosure Statement to Non-Institutional Customers (September 5, 2000), www.nasdr.com/filings/rf00_55.htm ,at page 2; See, NASD Notice to Members 00-61: NASD Regulation Files Rule Proposal With SEC Requiring Delivery Of Margin Disclosure Statement To Customers

[7] The 2341 Proposal at pages 6 -7 citing: On-Line Trading, Better Investor Protection Information Needed, Report to Congressional Requesters, GAO, General Government Division 00-43 (May 2000) [the “GAO Report”].

[8] 2341 Rule at pages 7-9.





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