—By Christopher H. Giampapa, Schulte Roth & Zabel LLP Christopher Giampapa is a special counsel in the Regulatory & Compliance and Litigation Groups at Schulte Roth & Zabel in the firm's New York office. He represents broker-dealers and other financial services companies in regulatory matters, government investigations and complex business disputes. The opinions expressed are those of the author(s) and do not necessarily reflect the views of the firm, its clients, or Portfolio Media Inc., or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice. [1] FINRA Regulatory Notice 11-25. [2] FINRA Rule 2010(d)(1). All Content © 2003-2016, Portfolio Media, Inc. .