Ebbe v. Concorde Investment Services, LLC, No. 19-1819 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed the judgment of the district court confirming a Financial Industry Regulatory Authority (FINRA) arbitral award denying certain claims against Concorde Investment Services, LLC, holding that the arbitrator's conclusion was reasonable in light of the claims made and the evidence presented.
Appellant's claims against Concorde were for negligence, breach of fiduciary duty, violations of FINRA sustainability rules and regulations against deceptive securities practices, and failure to properly supervise. Appellant's claims against Concorde were denied. Appellant filed a motion to vacate in part and confirm in part the award, and Concorde filed a motion to confirm the award. The district court denied the motion to vacate and granted the motion to confirm. The First Circuit affirmed, holding that the arbitrators did not engage in a manifest disregard of the law and that none of the statutory bases for vacating the awards set forth in the Federal Arbitration Act were met.