Public Finance Blog

Secrets, Surprises, Disclosures & Coming Clean

What happens if you know there are issues regarding your U5 or FINRA violations, and you really want to make a move?  Violations of various sorts can hold you back, if not handled correctly; however, if you have properly mitigated the circumstance, they can be handled effectively. Sharing your disclosure instead of holding and attempting to hide information does not bode well in this circumstance. 

Sharing Is Caring…And Helpful

The key to this is coming clean very early on in the process.  Sharing all information is crucial.  When it comes to FINRA violations, it depends if they fit into one of two categories: financially-related or other.  If there is a mark on your FINRA that has anything to do with a financial or client fiduciary relationship, this is much harder to mitigate.  Here, facts will really matter.  The date of the incident is also crucial.  If the violation was recent, it is going to be much harder for a firm to look past this, especially if it is related to financial mismanagement of any sort.  On the other hand, if it is not client-based and more personal, like a bankruptcy, HR may tend to be more forgiving on this disclosure.  Here’s the key to this whole process: they must know about all this prior to doing any research on you, the candidate. 

Surprise, Surprise!

Surprises are the worst thing that can happen when it comes to any disclosures on your detailed report.  Background data is paramount when you come clean to the hiring manager or recruiter.  If there has been any legal correspondence related to the incident, sharing all of that information will help mitigate the issue when the background check is done.  Personal infractions, such as a DUI and other types of misdemeanors, can also be addressed by most firms (if they know about the issue first).  Nothing kills a transition plan like a surprise.  The worst thing that can happen when you have a skeleton in your closet is to have it appear without any warning.  Now, let me be clear… many people do not have a clean FINRA in our industry.  Life happens, but dealing upfront with these unfortunate situations is the answer.

Big Or Small…Disclose It All

A FINRA violation or a disclosure should not hold you back from considering making a move.  But here’s another point you must consider: the closer the firm is to being a commercial bank or an affiliate of a commercial bank, the harder the look they are going to take.  A smaller firm will usually be easier to get past disclosure-related concerns, while a bulge bracket firm will be more difficult.  That’s not to say that it’s impossible, but there will be many more layers of approval for them to consider a banker without a clean record.  Entrepreneurial investment banking firms will be more tolerant if they know upfront that there are disclosures.  So, choose the firm you are interested in with the above in mind, come clean at the beginning of the process, and these disclosures may not prevent you from getting hired.

Conclusion

You don’t need a resume to chat with us! If you would like to discuss your options, please reach out for a confidential conversation at 760-477-1284 or email at harlan@hfriedmansearch.com. He can also be reached on LinkedIn. Harlan publishes a blog every Thursday here. Subscribe to our monthly newsletter here, which is a compilation of our weekly blogs, so you never miss one. We have also been mentioned in 2025’s Forbes, click HERE to read more.  

About Harlan Friedman, JD & Founding Member, H. Friedman Search LLC. Harlan is a thirty-year veteran Public Finance Banker turned recruiter who specializes in the placement of all levels Public Finance Bankers, Healthcare Bankers, Municipal Advisors, Compliance Officers, Issuers, and Bond Counsels.