"Let Go" at previous job, how do I address it on interviews?

I was let go by my previous employer in November of 2010. The employer was a small (~100 employees) broker/dealer specializing in distressed debt. I worked in the research division doing reorganized equities research and started in May of 2010. I graduated from Ross School of Business at Michigan in Jan 2010.

During my time at this employer, I completed three major research reports on post-bankruptcies. I also did not take the Series 7 or 6, so I have no U4 form. The reason I was let go is explained in the following:

I worked for the employer for 6 months where I completed three reorg equity write ups. The rules of working on the research team were not adequetely explained to me except that I had to disclose any personal accounts so the company could track my monthly statements. There was zero training program at this job. Additionally, I was not allowed to trade any stock we put a report out on for three days thereafter. The compliance person didnt bother to call my broker and get my montly statements until I was 6 months into the job, where he noticed that I had traded a certain equity up until October 22, 2010. I had been doing preliminary research on that equity in mid to late October but had sold out on October 22, 2010. I started research on that company for a full write up in early November. The compliance person saw these trades in October and put it to the attention of the CEO. The CEO stated that I had violated company policy and I was let go from the company promptly.

Right now I am currently looking for a BB job in S&T or IBD, or a job at a MM firm doing IBD. How should I go about explaining my previous job. I spoke with my previous employer and my status is "terminated" with no U4 form or comments. Should I even have this job on my resume? If not what should I say I was doing from Jan 2010- now? Thanks in advance.

 
Best Response

Value... sorry to hear that.

While I would be honest about this if asked, you broke FINRA Rule 407. That's a BIG NO NO! Basically, you could have potentially been engaging in any sort of potentially dubious outside trading while working for a registered financial institution. I have three questions for you that will clarify these things:

1) Did you inform your firm where your outside accounts were being held, what the account numbers were and provide your broker with authorization to have statements sent to your employer? 2) Was the security in question a stock that the company you worked for routinely covered by your firm? Where you assigned to start coverage on the stock? What exactly do you mean by preliminary research? 3) What was the firm's policy on trading in an equity during a "research period" or was there a "Restricted List" that you violated by trading in this security?

I ask these, because I'm looking for more color on your story. The fact is, ignorance is no excuse and you screwed up. Yes, no one explained it to, and I get that. I really do. I wouldn't expect a kid 6 months out of college to know their firm's policies on everything, but if you had a question as to what you could and couldn't do regarding your own account, you should have asked. I would expect that even at the most basic orientation, if the firm is big enough that it has ~100 employees, I'm sure that you had an orientation where this was briefly addressed. If it wasn't clear then, you should have asked questions about it.

Hell, I know my firm's PA policy like the back of my hand if I want to make trades, and we have serious policies about what we can and can't trade, how long we need to hold it and what securities are ineligible from even being looked at.

I realize I'm being harsh and thank god you don't have a U-4, but don't leave the experience off your resume, despite being fired. Worse things have happened than this and you can chalk it up to no one explaining how your firm's PA policy worked, particularly to a new kid out of college.

 

1) Did you inform your firm where your outside accounts were being held, what the account numbers were and provide your broker with authorization to have statements sent to your employer? -Yes, on my first day of employment I gave the complaince officer the account numbers and address of record and authorized him to receieve monthly statements. He failed to follow up on this and did not receieve my monthly statements until he asked me to send him September and October statements by email. 2) Was the security in question a stock that the company you worked for routinely covered by your firm? Where you assigned to start coverage on the stock? What exactly do you mean by preliminary research? The stock was not covered at all by the company at any previous time. By preliminary research, I was working on a distribution sheet which was informational only and laid out all the classes in bankruptcy and their respective distributions. I was assigned to start coverage on the stock in November, after I had sold the stock on October 22. We put out that distribution sheet around when I sold the stock, but the company didnt even restrict the security for the whole firm, claiming it was informational only (no opinion). 3) What was the firm's policy on trading in an equity during a "research period" or was there a "Restricted List" that you violated by trading in this security? The only rule I was aware of was that if a research report was sent out to clients, the stock was restricted for 3 business days. They never gave me a rule book or a training course on restrictions during a "research period". Additionaly, I dont even think I broke that rule anyway, from the information I previously discussed.

Thanks for the informed reply. I agree that I should leave it on my resume and just be honest about what happened. I did complete some solid reports there so I have alot to talk about.

 

Thanks for some detail. I do have a few more follow up questions...

1) When you gave your employer everything, did you also contact your broker and have the broker add your firm and the compliance officer as an "Interested Party" on your PA to ensure that they recieved statements? 2) When you did the Preliminary Research, where you asked to do that by your employer or were you looking at opportunities to present on your own time?

 

1) When you gave your employer everything, did you also contact your broker and have the broker add your firm and the compliance officer as an "Interested Party" on your PA to ensure that they recieved statements? -I didnt do this as I was not told to do this.
2) When you did the Preliminary Research, where you asked to do that by your employer or were you looking at opportunities to present on your own time? -I was asked not by my boss, but by the head trader to do the distribution sheet. I was than asked by my boss to do the actual research report at the end of October, early November.

 

First of all, it sounds like they were right to fire you. It's a stiff punishment, and I'm completely sympathetic to your plight, but you fucked up and were caught in a situation that could have been far more damaging than it was. Yes, I know it's a misunderstanding and you didn't know the rules, but it doesn't matter, as it's not an excuse. I'm sorry to say this, but you did two things that were wrong here and both can be considered serious problems. The first was the Rule 407 violation and the second was trading in a security that you were doing research on.

Rule 407 and making your Firm an "Interested Party" on your PA - did you think of asking about it? If you give me your broker's name and account number and a verbal "OK, call 'em and get what you need", I won't be able to get shit from them. Even though you gave compliance your account number and broker's name and number, they could not call and ask for your info. It's a client confidentiality thing. You had to call your broker and say it's okay for them to talk to your compliance group and you needed to add them as an interested party who could recieve statements and trade confirms. That's a Rule 407 violation. I know people who have been fired for Rule 407 violations, as trading outside the firm, particularly unmonitored trading, allows for insider trading, frontrunning and trading alongside clients without anyone seeing you do it. If you bought the stock without knowing while doing research and they saw the trade confirms happen, it'd be a bit easier to call you in and say sell out, close the position and never do it again instead of this happening, from what it sounds like, as way after the fact.

The Preliminary Research - Again, did you ask whether your distribution sheet counted as "being covered" or part of the research process? Yes, you were told you can't trade in a security for 3 days after research is released, but you also couldn't trade in it while you were doing any research on that security. The moment you were asked to do even any preliminary work, it should have crossed your mind, especially if you wanted to trade in the security in question, about whether trading in that name was Kosher. I don't know how you do your research or what sources you use, particularly if they are non-public material sources, but you could have potentially violated a whole slew of rules and regs that would have gotten you in major trouble. Couple the simple fact that you were told by a superiour you had to do preliminary research for a distribution sheet with the rather apparent trading you did in the security, and it's not hard to create a causal link between the two that you did something that could have been a major nightmare.

Whether it's not explained right or not even discussed, you should have asked about it regardless. If you don't know or are unfamiliar, ask a question. I mean, if you had your U-4, it'd be a major issue, as they would need to detail what happened and why you were terminated. Not knowing is never an excuse.

I know I'm being harsh, but that's the reality of things. It sucks... but learn for next time.

 

"I don't know how you do your research or what sources you use, particularly if they are non-public material sources, but you could have potentially violated a whole slew of rules and regs that would have gotten you in major trouble" -all material was public information available on PACER

frieds, thanks for the straight talk....I agree with you completely. I have since closed down all my PA's and dont plan to have one until i truly understand the next company's policies and all the SEC/FINRA rules. It was definately a learning experience and hopefully it wont hurt my chances at getting a new job.

And yes, I was never registered so I do not have a U-4. I think this will just be a learning experience and no real permanent damage done.

In fact, when I applied for unemployment, my old company called me up and said that technically I resigned and that I would not receive unemployment. I told the accounting person that I was terminated and that I should receieve unemployment. He said that they put me down as resigning so they wouldnt have to add comments on my U-4, which I proceeded to tell him that I did not have. So I am now listed as terminated and will receive unemployment.

 

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