Updated as of March 19, 2021Initial Pre-Hearing ConferenceArbitrator’s Script[The script is in a regular typeface size. Information in brackets, in italics, isintended to clarify a point for the arbitrator and does not need to be read to theparties. The arbitration panel must be prepared for the conference call and have itsschedule/calendar available. Please dial-in a few minutes before the call isscheduled to begin. A Verizon operator will NOT contact you. You will need thecase number to give to the operator.The panel Chairperson has the responsibility to record the agreements reachedduring the conference on the Initial Pre-hearing Conference Scheduling Order(Scheduling Order). The Chairperson should submit the enclosed Scheduling Order toFINRA Dispute Resolution Services within 48 hours. The Chairperson may do soby electronic mail.The Initial Pre-hearing Conference (IPHC) procedures set forth below should befollowed, but may, in the panel’s discretion, be varied to allow all parties a full andfair opportunity to present their respective positions. If a member of the FINRADispute Resolution Services staff participates in the conference, he or she shouldspeak with the Chairperson before the IPHC to discuss their respective parts of thescript. If a staff member is present, he/she will begin by introducing the arbitrators. If astaff member is not present, the Chairperson will perform this function.]A. Introduction of the Arbitrators: We will begin by briefly introducing ourselves.As a reminder, I/we have been selected to serve as neutral arbitrators to hear anddecide this matter. I/we are not FINRA Dispute Resolution Services employee(s).I/we are independent arbitrators. FINRA makes available this arbitration forum—pursuant to rules approved by the SEC—but has no part in deciding the award.Will the parties or their representatives introduce themselves and any others who arelistening on their end of the line? Since we cannot see each other, please continueto identify yourself by name whenever you speak.For Special Proceedings Only:This confirms that the hearing in this matter will be conducted as a SpecialProceeding via telephone conference call. The following hearing procedures willbe followed:

Claimants, collectively, and respondents, collectively, each have twohours to present their cases and one-half hour for rebuttal and closingstatements;The hearing will be completed in one day with no more than twohearing sessions;The parties may not question or cross-examine the opposing parties’witnesses; andThe parties may not call an opposing party as a witness.(Cases Proceeding Under the Expedited Procedures for Senior or SeriouslyIll Parties Program):We have been informed that this is an expedited case involving senior orseriously ill parties. FINRA’s procedures call for the scheduling of hearing dates thatwill expedite the process, but still provide a reasonable amount of time for casepreparation. We remind the parties that it is better to set aside extra dates to avoiddelay in the arbitration process.The arbitrators promise to avoid causing postponements, absent a genuineemergency. We also pledge to be prepared and on time for all conferences andhearings. In exchange, we expect the parties and counsel to avoid unnecessarypostponements, to be prepared, and to be on time, for all conferences andhearings.B. Disclosures: The panel will now make any disclosure that was not previouslycontained in the Arbitrator Disclosure Report. Arbitrators should confirm on therecord their current classifications as either public or non-public arbitrators.[Arbitrator disclosure is the cornerstone of FINRA arbitration, and thearbitrator’s duty to disclose is continuous and imperative. Disclosureincludes any relationship, experience and background information that mayaffect—or even appear to affect—the arbitrator’s ability to be impartial and theparties’ belief that the arbitrator will be able to render a fair decision. Whenmaking disclosures, arbitrators should consider all aspects of theirprofessional and personal lives and disclose all ties between the arbitrator, theparties and the matter in dispute, no matter how remote they may seem. If youneed to think about whether a disclosure is appropriate, then it is: MAKE THEDISCLOSURE. This shall include all disclosures previously made, includingany disclosures resulting from the Arbitrator Disclosure Checklist, in addition tonew disclosures. Arbitrators are reminded that any change in theirclassification as a public or non-public arbitrator must also be disclosed.]As Chairperson, I have the following disclosures [convey disclosure, ifappropriate].Do any of the parties and counsel to this matter know of any potential conflictsbetween the arbitrators and any party, counsel or witness in this matter?2

C. Confirmation of the Panel: Do the parties confirm acceptance of the panel’scomposition?D. Oath of Arbitrators: As Chairperson, I confirm that I have executed my oathand submitted it to FINRA Dispute Resolution Services. Have the otherpanelists submitted their oaths?[If not, inquire as to whether each arbitrator has read and reviewed FINRA’sTemporary and Permanent Arbitrator Disqualification Criteria, the ArbitratorDisclosure Checklist, and the Arbitrator Disclosure Report. If an arbitrator hasnot received and reviewed the above items, he/she is not permitted to rule onany item on today’s agenda.]If he/she has reviewed the items, then administer the oath as follows:“Do you, as an arbitrator(s) selected to hear this matter incontroversy, solemnly swear or affirm your duty under the AAA/ABACode of Ethics for Arbitrators in Commercial Disputes to keepconfidential all matters relating to this arbitration proceeding anddecision, including but not limited to any information, documents,evidence, or testimony presented; and that your duty is continuous anddoes not cease at the conclusion of the arbitration or upon yourwithdrawal as an arbitrator?Do you solemnly swear or affirm that you are not an employer of,employed by, or related by blood or marriage to any of the parties orwitnesses whose names have been disclosed to you; that you have nodirect or indirect interest in this matter; that you know of no existingor past financial, business, professional, family, or social relationshipwhich would impair you from performing your duties; andThat you will decide the controversy in a fair manner, and render ajust award?Do you swear or affirm that, based on FINRA Dispute ResolutionServices’ Temporary and Permanent Arbitrator Disqualification Criteria;you are not temporarily or permanently disqualified from being aFINRA arbitrator?Having reviewed the Arbitrator Disclosure Checklist, do you certifythat you have made all disclosures of items on the ArbitratorDisclosure Checklist?Do you swear or affirm that your Arbitrator Disclosure Report isaccurate, current, and up to date, and that you have no additionaldisclosures to make?”The Chairperson should make sure that the oaths are executed in writing andgiven to the FINRA Dispute Resolution Services staff for completion of the casefile.]3

E. Pleadings: We acknowledge and identify that the following pleadings have beenfiled by the parties and read by the panel: [list documents]. Acknowledge anyoutstanding deficiencies (e.g. undated submission agreement, unpaid fees orfailure to file proof of service) and set a deadline for parties to cure suchdeficiencies. Remind parties that if the filing party does not correct thedeficiency by the deadline, the Panel will proceed as though the deficientdocument had not been filed.[If one of the parties has failed to submit a signed Submission Agreement,please advise the parties of the following:]Any party that has not yet filed a Submission Agreement or otherwise objected tojurisdiction must do so within 30 days or may be subject to sanctions as providedin the Codes of Arbitration Procedure (Codes).[If one of the parties has failed to submit an answer (an unresponsive party), FINRAstaff will review the service history with the panel and ask the panel to decidewhether service is complete and sufficient upon the unresponsive party in order for thecase to proceed to hearing].F. Mediation: We want to remind the parties that FINRA Dispute Resolution Serviceshas a successful, voluntary mediation program. Mediation is an informal processin which a mediator facilitates negotiations between disputing parties. Themediator’s role is to help the parties find a mutually acceptable solution to thedispute. Parties who mediate at this forum resolve four out of every five cases.FINRA Dispute Resolution Services mediators are trained and experienced inhelping parties resolve their disputes. In addition, many are experiencedarbitrators, attorneys, and securities industry professionals knowledgeable inemployment and securities issues.The mediation process is designed to proceed on a parallel track with thisarbitration, so it does not interfere with the scheduled hearing dates or othermatters agreed to during the course of this pre-hearing conference. If you areinterested in mediation, contact the staff member assigned to this case for moreinformation.COVID-19 Reduced Fee ProgramFINRA is currently offering to parties in arbitration cases the remote use of themediation process (via Zoom and/or by telephone) at a reduced rate. The COVID19 Reduced Fee Program features the following benefits:o Parties will receive a random list of 10 national mediators along with theirMediator Disclosures for consideration and ranking;o The mediator payment for his/her service is 100 an hour split by theparties; ando FINRA waives mediation filing fees and administrative fees (FINRAreceives no revenues)4

If interested in participating in this program, please advise your Case Administratorwho will have the appropriate Mediation Administrator contact the parties to discussfurther and help assist with scheduling the virtual mediation.[As a reminder, the IPHC procedures set forth below should be followed, but may,in the panel’s discretion, be varied to allow all parties a full and fair opportunityto present their respective positions.Further, it is within the panel’s discretion to determine the order in which theparties and arbitrators discuss scheduling hearings or setting discovery, motion, orbriefing deadlines. Regardless of the order, the panel should endeavor to meetFINRA’s goal of scheduling hearings within nine months or less after thisconference.]G. Additional Guidance for Cases Involving Pro Se Parties:Since we have parties that are appearing without counsel in this matter, I want toadd some further background on the arbitration process. As arbitrators, ourultimate responsibility is to resolve all claims in a fair and just manner. To theextent ethically permissible, we will provide parties with procedural guidance anddirection to ensure that all parties receive a fair hearing. However, arbitrators will notand cannot be an advocate for any party, nor can we offer legal advice orrecommend a specific course of action. If you need legal advice at any timeduring this case, we recommend that you consult with an attorney. Please note thatFINRA rules provide parties with the right to be represented by a lawyer at any timein the proceeding.Are there any questions?H. Late Cancellations - Party and Arbitrator Communication: The parties andarbitrators may arrange for direct communication solely to alert the panel that theparties have settled the case, the claimant has withdrawn the claim, or the partiesjointly agreed to postpone the hearings. This arrangement prevents arbitratorsfrom unnecessarily traveling to a cancelled hearing. Do the parties agree to directcommunication solely to alert the panel that the parties have settled the case, theclaimant has withdrawn the claim, or the parties jointly agreed to postpone thehearings?[If the parties agree to direct party and arbitrator communication or directcommunication solely to alert the panel that the parties have settled the case, theclaimant has withdrawn the claim, or the parties jointly agreed to postpone thehearings, the Chairperson should record the parties’ agreement in the Order.]I. Party and Arbitrator Communication: We remind the parties that they may notcommunicate with any member of the panel except in the presence of all parties orrepresentatives. All correspondence and pleadings must be filed with the FINRAOffice of Dispute Resolution Services via the DR Portal for distribution to thepanel.[Please select either K or L below, as appropriate, to schedule hearing dates.]5

J. Postponement FeeFINRA charges a postponement fee for all postponed hearings equal to theapplicable hearing session fee. The arbitrators may allocate the fee to the party oramong the parties that agreed to or requested the postponement. FINRA will notcharge this fee if the parties advise FINRA that they have reached a finalsettlement and the case can be closed.Payments to Arbitrators - Postponements or Cancellations within 10 Days ofa HearingSeparate from the above postponement fee, if a party requests and thearbitrators grant, a postponement within ten days before a scheduled hearingsession, the party making the request shall pay an additional fee of 600 perarbitrator (a total of 1,800 for cases with three arbitrators). This fee alsoapplies if a hearing is cancelled because the parties have settled the case.The parties should understand that they have 10 days before the first scheduledhearing date to advise FINRA of the postponement or settlement of the case toavoid the 600 per arbitrator late cancellation fee.Question to Parties: On what date was this case filed?The above paragraph applies to cases filed on or after July 6, 2015.K. Selection of Arbitration Hearing Dates (Special Proceeding):[Now schedule the arbitration dates. During the IPHC, dates are to be setregardless of a party’s failure to prepare for the selection of any of the