The following excerpt is from Fleming v. Charles Schwab Corp., 878 F.3d 1146 (9th Cir. 2017):
that makes a securities trade without disclosing a conflict of interest violates federal securities law.... [A] broker-dealer that fails to achieve best execution for a customer by arranging a trade whose terms favor the dealer rather than the client has a securities problem, not just a state-law contract or fiduciary-duty problem."); cf. Rayner v. E*TRADE Finl Corp. , 248 F.Supp.3d 497, 503 (S.D.N.Y. 2017) (finding allegations "that E*TRADE routed orders to maximize kickback revenue" SLUSA-barred) (internal quotation marks omitted).
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