The Wisconsin Department of Financial Institutions, Division of Securities's Authority

Wisconsin Attorney General Josh Kaul and the Wisconsin DFI Division of Securities have authority under the Wisconsin Uniform Securities Law (Wis. Stat. Ch. 551) to investigate broker-dealer conflicts. Given Griffin's donations to Wisconsin Banking Committee members, the AG's independence is particularly valuable.

The Harm Requiring Regulatory Response

Wisconsin's manufacturing and dairy economy has a large working-class retail investor population. Griffin's significant political investment in Wisconsin — including to Senator Ron Johnson of the Senate Banking Committee — raises serious questions about regulatory capture.

What State Regulators Should Do

The Wisconsin Department of Financial Institutions, Division of Securities, in coordination with the Wisconsin Attorney General's office, should:

• Open an investigation into whether broker-dealers serving Wisconsin residents are meeting best execution obligations under state securities law
• Issue a formal inquiry to major PFOF-dependent brokers about their routing arrangements with Citadel Securities and the execution quality they achieve for Wisconsin residents
• Contact NASAA to explore multistate coordination
• Issue investor education guidance about PFOF practices and how Wisconsin investors can protect themselves
• Consider rulemaking under state securities law to require enhanced disclosure of PFOF arrangements affecting Wisconsin retail investors

Contacting the Wisconsin Department of Financial Institutions, Division of Securities

Wisconsin investors and advocates can contact the Wisconsin Department of Financial Institutions, Division of Securities at https://www.wdfi.org/securities to report concerns and request regulatory action on PFOF practices affecting Wisconsin residents.