Jurisdictional and Immunity Barriers to Challenging FINRA Arbitrations and BrokerCheck Disclosures:
Commentary on Tanjutco v. NYLife Securities LLC (2d Cir. Dec. 9, 2025)

I. Introduction

This commentary examines the Second Circuit’s summary order in Carolina P. Tanjutco v. NYLife Securities LLC, et al., No. 24‑2666‑cv (2d Cir. Dec. 9, 2025). Although issued as a “summary order” without precedential effect under the court’s local rules, the decision is a compact but important illustration of several recurring federal‑court doctrines:

The strict requirement of a statutory waiver for suits against federal agencies (sovereign immunity).
The scope of arbitral immunity and self‑regulatory organization (SRO) immunity in the securities industry.
The jurisdictional limits on petitions to confirm or vacate arbitration awards under the Federal Arbitration Act (FAA), especially after Badgerow v. Walters.
The tricky status of U.S. citizens domiciled abroad for diversity jurisdiction purposes.

The petitioner, Carolina P. Tanjutco, proceeding pro se, sought to confirm in part and vacate in part a FINRA arbitration award involving NYLife Securities LLC and New York Life Insurance Company (collectively, “New York Life”). She also attacked alleged defamatory disclosures on her regulatory record (CRD/BrokerCheck) and sought to hold FINRA and the SEC responsible for those disclosures and for alleged due process violations.

The Southern District of New York (Magistrate Judge Moses, on consent) dismissed her amended petition, holding:

It lacked subject‑matter jurisdiction over claims against the SEC (sovereign immunity) and New York Life (no independent federal jurisdiction under the FAA).
Her claims against FINRA failed as a matter of law because FINRA enjoys absolute immunity both as an arbitration forum and as a securities SRO.

On appeal, the Second Circuit affirmed in full, reinforcing several significant jurisdictional and immunity principles that often confront litigants seeking to challenge FINRA arbitrations and associated regulatory disclosures.

II. Summary of the Opinion

A. Procedural Background

Initial petition. Tanjutco filed in the Southern District of New York a petition under the FAA to confirm in part and vacate in part a FINRA arbitration award. She named NYLife Securities LLC, New York Life Insurance Company, and Carol Maria Luttati (identified as acting Chair of FINRA).
The district court, on its own initiative, dismissed for lack of subject‑matter jurisdiction but granted leave to amend. See Tanjutco v. NYLife Sec. LLC, 2023 WL 4848465 (S.D.N.Y. July 27, 2023).
Amended petition. Tanjutco then filed an amended petition, now naming:
- NYLife Securities LLC and New York Life Insurance Company (“New York Life”),
- FINRA, and
- The U.S. Securities and Exchange Commission (SEC).
The respondents moved to dismiss. The district court again dismissed, ruling:
- no jurisdiction over claims against the SEC (sovereign immunity),
- no jurisdiction over claims against New York Life (no federal question and no diversity in an FAA petition), and
- failure to state a claim against FINRA due to arbitral and regulatory immunity.
See Tanjutco v. NYLife Sec. LLC, 2024 WL 4135686 (S.D.N.Y. Sept. 10, 2024).
Appeal. Tanjutco appealed pro se to the Second Circuit, which affirmed the judgment.

B. Standards of Review

The Second Circuit applied familiar review standards:

Rule 12(b)(1) dismissals for lack of subject‑matter jurisdiction:
- Factual findings: clear‑error review.
- Legal conclusions: de novo (no deference). See Aurecchione v. Schoolman Transp. Sys., Inc., 426 F.3d 635, 638 (2d Cir. 2005).
Rule 12(b)(6) dismissals for failure to state a claim:
- De novo review.
- The complaint must allege facts which, taken as true and with reasonable inferences in plaintiff’s favor, state a plausible claim. See Sharikov v. Philips Med. Sys. MR, Inc., 103 F.4th 159, 166 (2d Cir. 2024).
Pro se pleadings are construed liberally to raise the strongest claims they suggest (citing Sharikov).

C. Holdings

Claims against the SEC – barred by sovereign immunity.
The SEC, as a federal agency, is protected by sovereign immunity unless Congress has unequivocally waived that immunity in a statute covering the type of claim asserted. Tanjutco alleged federal due process violations relating to FINRA's BrokerCheck and CRD disclosures and sought damages. She pointed to no statutory waiver allowing such suits against the SEC, and none was apparent. The district court therefore lacked jurisdiction.
Claims against FINRA – barred by arbitral and regulatory immunity.
To the extent Tanjutco challenged FINRA’s role in the underlying arbitration, FINRA is protected by absolute arbitral immunity, which extends to sponsoring organizations. To the extent she challenged FINRA’s regulatory activities, including BrokerCheck disclosures, FINRA enjoys absolute immunity as an SRO for actions taken in the discharge of its regulatory responsibilities.
Claims against New York Life – no federal jurisdiction over FAA petition.
The FAA authorizes petitions to confirm or vacate arbitration awards but does not itself confer federal jurisdiction. Following Badgerow, the court cannot “look through” to the underlying arbitration dispute; instead, a jurisdictional basis (federal question or diversity) must appear on the face of the petition itself.
- No federal question jurisdiction: While Tanjutco invoked constitutional due process and interstate commerce, she sued a private party (New York Life) and did not allege state action or “color of state law,” which is essential for a constitutional claim against non‑government actors. Therefore no cognizable federal claim appeared on the face of the petition.
- No diversity jurisdiction: New York Life is a New York citizen. Tanjutco alleged either that she resided in New York or that she was a dual U.S. citizen living abroad in the Philippines. Either way:
  - If she was domiciled in New York, there was no complete diversity.
  - If she was a U.S. citizen domiciled abroad, she is “stateless” for § 1332 purposes, meaning diversity jurisdiction is unavailable.
Without an independent jurisdictional basis, the district court could not entertain the petition to confirm or vacate the award.

III. Precedents and Authorities Cited

A. Sovereign Immunity and Suits Against the United States / SEC

United States v. Mitchell, 463 U.S. 206 (1983)
Reaffirmed that the United States cannot be sued without its consent and that consent must be found in an explicit statutory waiver. This case is the foundation for the “axiomatic” rule quoted in later Second Circuit opinions.
Adeleke v. United States, 355 F.3d 144 (2d Cir. 2004)
Cited for the proposition that sovereign immunity bars suits against the United States (and its agencies) absent an unequivocal statutory waiver, and that waiver is a prerequisite to jurisdiction.
Binder & Binder, P.C. v. Colvin, 818 F.3d 66 (2d Cir. 2016)
Emphasized that waivers of sovereign immunity must be “unequivocally expressed in statutory text” and cannot be implied.

Applied here, these authorities underscore that a plaintiff cannot rely on general constitutional principles or regulatory objections to circumvent sovereign immunity; there must be a statute specifically authorizing the type of suit brought against the federal agency.

B. Arbitral Immunity and SRO Immunity

Austern v. Chicago Bd. Options Exch., Inc., 898 F.2d 882 (2d Cir. 1990)
Held that arbitrators in contractually agreed arbitration proceedings are absolutely immune from damages for all acts within the scope of the arbitral process, and that this immunity extends to the sponsoring organization (e.g., Chicago Board Options Exchange).
The Second Circuit extends this reasoning to FINRA: as the entity administering the arbitration, FINRA cannot be sued for damages arising out of its conduct in that arbitral role.
Standard Inv. Chartered, Inc. v. Nat’l Ass’n of Sec. Dealers, Inc., 637 F.3d 112 (2d Cir. 2011)
Confirmed that SROs and their officers are absolutely immune from private damages suits arising from the discharge of their regulatory responsibilities. This covers rulemaking, enforcement, disciplinary actions, and related disclosure mechanisms.
Cohen v. UBS Fin. Servs., Inc., 799 F.3d 174 (2d Cir. 2015)
Reiterated that FINRA is an SRO and, by implication, within the ambit of the immunity defined in Standard Investment.

These cases together demonstrate that litigants cannot obtain damages from FINRA either for its role in administering arbitration or for its performance of regulatory functions, including maintaining and publishing CRD/BrokerCheck information.

C. Federal Arbitration Act and Jurisdictional “Look‑Through”

Badgerow v. Walters, 596 U.S. 1 (2022)
The Supreme Court held that for FAA §§ 9 and 10 (confirmation and vacatur), federal courts may not “look through” the petition to the underlying substantive dispute to find federal jurisdiction. The “look‑through” approach is limited to § 4 (petitions to compel arbitration) under the statutory language discussed in Vaden v. Discover Bank.
Thus, a petition to confirm or vacate an arbitration award must show on its face either:
- a federal question (claim arises under federal law), or
- diversity of citizenship and requisite amount in controversy.
The FAA itself is not jurisdiction‑conferring.
Trustees of N.Y. State Nurses Ass’n Pension Plan v. White Oak Glob. Advisors, LLC, 102 F.4th 572 (2d Cir. 2024)
The Second Circuit applied Badgerow to hold that an independent jurisdictional basis must appear on the face of the application itself, not by reference to the underlying arbitration claims.
Tanjutco relies on this to reject any attempted “look‑through” to the underlying arbitration dispute.

D. Federal Question: State Action Requirement

McGugan v. Aldana‑Bernier, 752 F.3d 224 (2d Cir. 2014)
Clarified that to bring a constitutional claim against a private party, the plaintiff must show that the defendant acted “under color of state law” – essentially, that the private party’s conduct is fairly attributable to the state (a requirement borrowed from § 1983 jurisprudence).
In Tanjutco, New York Life is a private entity, and the petitioner did not plausibly allege any state action.
City of New York v. Exxon Mobil Corp., 154 F.4th 36 (2d Cir. 2025)
Reiterated that federal question jurisdiction generally exists only where a federal question is presented on the face of the well‑pleaded complaint. Simply invoking federal concepts or referencing federal statutes is not enough; there must be a properly pleaded federal “cause of action.”

E. Diversity Jurisdiction, Corporate Citizenship, and “Stateless” U.S. Citizens

28 U.S.C. § 1332
Provides for diversity jurisdiction where:
- the amount in controversy exceeds $75,000, and
- the dispute is between citizens of different U.S. states, or between a U.S. citizen and a foreign citizen/subject (with additional complexities not implicated here).
Bayerische Landesbank, N.Y. Branch v. Aladdin Cap. Mgmt. LLC, 692 F.3d 42 (2d Cir. 2012)
Explained:
- A corporation is a citizen of its state of incorporation and the state of its principal place of business.
- An LLC takes the citizenship of each of its members.
Here, New York Life was a citizen of New York, and there was no allegation that would alter that conclusion.
Herrick Co. v. SCS Commc’ns, Inc., 251 F.3d 315 (2d Cir. 2001)
Crucially held that U.S. citizens domiciled abroad are neither citizens of a U.S. state nor “citizens or subjects of a foreign state” for purposes of § 1332. As a result, diversity jurisdiction does not exist in suits where such “stateless” U.S. citizens are parties.
In Tanjutco, if the petitioner was a U.S. citizen domiciled in the Philippines, then there was no valid diversity basis at all under Herrick.

F. Standards of Review Cases

Aurecchione v. Schoolman Transp. Sys., Inc., 426 F.3d 635 (2d Cir. 2005) – standard for Rule 12(b)(1) review.
Sharikov v. Philips Med. Sys. MR, Inc., 103 F.4th 159 (2d Cir. 2024) – plausibility standard under Rule 12(b)(6) and liberal construction of pro se pleadings.

IV. Legal Reasoning in Depth

A. Claims Against the SEC: Sovereign Immunity

1. Nature of the Claim

Tanjutco asserted that her “right to federal due process” was violated when the SEC authorized FINRA to enter disclosure reports in FINRA’s Central Registration Depository (CRD), which are publicly accessible via FINRA’s BrokerCheck system. She sought damages allegedly arising out of the “defamatory disclosures placed on her record.”

Functionally, this is a damages‑based constitutional tort claim against a federal agency for its regulatory oversight of an SRO. The Second Circuit treated it accordingly.

2. Requirement of a Statutory Waiver

Applying Mitchell, Adeleke, and Binder & Binder, the court emphasized:

The United States and its agencies cannot be sued without congressional consent.
The consent (waiver of sovereign immunity) must be explicit in statutory text.
Courts cannot infer or imply a waiver from generalized principles or from the mere existence of a regulatory scheme.

Tanjutco did not identify any statute that:

authorizes damages suits against the SEC for approving or overseeing SRO disclosure systems, or
creates a cause of action for constitutional due process violations by the SEC in this context.

Moreover, there was no suggestion that the SEC had any direct role in the arbitration itself. The asserted wrong was the SEC’s overarching oversight of FINRA’s disclosure system, which falls squarely within its regulatory function – precisely the kind of area where sovereign immunity is typically robust absent a specific statutory remedy (e.g., APA review of certain final agency actions, which was not properly invoked here).

3. Jurisdictional Consequence

Without a statutory waiver, the district court lacked subject‑matter jurisdiction over the claims against the SEC. Sovereign immunity is not a mere defense on the merits; it is a jurisdictional bar. Accordingly, dismissal under Rule 12(b)(1) was mandatory.

B. Claims Against FINRA: Arbitral and SRO Immunity

1. Arbitral Immunity for the Arbitration Itself

To the extent Tanjutco’s claims concerned how FINRA conducted or managed the underlying arbitration (e.g., the conduct of the arbitrators, the fairness of the proceeding, scheduling, rulings, etc.), FINRA was protected by arbitral immunity.

Under Austern:

Arbitrators are absolutely immune from damages for acts within the scope of the arbitral process.
This immunity extends to the sponsoring organization that administers the arbitration (here, FINRA).

“Within the scope of the arbitral process” includes all actions necessary or related to the arbitration’s conduct – selection of arbitrators, procedural rulings, management of hearings, and issuance of awards. Parties dissatisfied with an arbitration outcome may seek narrow statutory review (e.g., FAA § 10), but they cannot sue the arbitrator or the forum for damages arising from the arbitration’s conduct.

2. SRO Regulatory Immunity for BrokerCheck/CRD

To the extent Tanjutco challenged FINRA’s management of BrokerCheck and CRD, and claimed damages from “defamatory disclosures” on her record, the court invoked Standard Investment and Cohen:

FINRA, as an SRO, performs quasi‑governmental regulatory functions delegated by the SEC (e.g., licensing, monitoring broker behavior, enforcing rules, and maintaining public disclosure systems).
SROs and their officers enjoy absolute immunity from private monetary damages suits for conduct undertaken in the discharge of these regulatory responsibilities.

Maintaining and publishing CRD/BrokerCheck information is central to FINRA’s investor‑protection mandate. Courts have consistently treated such functions as regulatory, not commercial. Thus, even if Tanjutco believed the disclosures were false or defamatory, her damages claims were barred by SRO immunity.

The opinion does not suggest that Tanjutco sought non‑monetary remedies (e.g., injunction or expungement) via the limited procedural routes that might, in some settings, be available. The analysis is confined to damages, and on that front, immunity is absolute.

C. Claims Against New York Life: Subject‑Matter Jurisdiction Over FAA Petitions

1. FAA as Non‑Jurisdictional

Tanjutco’s core litigation posture was a petition under the FAA to confirm in part and vacate in part a FINRA arbitration award. Under Badgerow and White Oak:

The FAA authorizes certain actions (e.g., petitions to compel, confirm, or vacate arbitration), but it does not itself confer federal subject‑matter jurisdiction.
For §§ 9 and 10 petitions, courts cannot “look through” the petition to the underlying arbitration dispute to find a federal question; they must look only to the face of the petition.

Therefore, to be in federal court, Tanjutco needed either:

a well‑pleaded federal claim apparent on the face of the petition (federal question), or
properly alleged complete diversity of citizenship and requisite amount in controversy (diversity).

2. Federal Question Jurisdiction: No State Action, No Claim

Tanjutco attempted to invoke constitutional due process and asserted that the matter involved interstate commerce. The Second Circuit held these contentions insufficient for federal question jurisdiction.

Two key points:

Private defendant, no state action.
Constitutional claims (e.g., due process, equal protection) generally require that the defendant be a government actor or a private actor whose conduct is fairly attributable to the state (“under color of state law”). Under McGugan, a private party like New York Life is not subject to constitutional claims unless it is performing a traditionally exclusive state function or is in close nexus with the state. None of that was alleged.
Well‑pleaded complaint rule.
As City of New York v. Exxon Mobil reiterates, the presence of a federal issue must appear on the face of the complaint as a cause of action, not merely in the background facts or in passing references. Here, the petition did not assert a cognizable federal cause of action against New York Life; it primarily sought FAA relief and invoked constitutional concepts in a conclusory way.

Accordingly, there was no federal question jurisdiction over the petition against New York Life.

3. Diversity Jurisdiction: New York Citizenship and “Stateless” U.S. Citizens

For diversity jurisdiction, the court examined the citizenship of the parties:

New York Life:
It was undisputed that New York Life was a citizen of New York. Whether viewed as a corporation or LLC for jurisdictional analysis, it was anchored in New York under Bayerische Landesbank.
Tanjutco:
She described herself as either:
- a resident of New York, or
- a dual American citizen living abroad in the Philippines.

The court explained that:

If Tanjutco was domiciled in New York, there is no complete diversity because both she and New York Life are citizens of the same state.
If she was a U.S. citizen domiciled abroad, then under Herrick, she is “stateless” for purposes of § 1332 – neither a citizen of any U.S. state nor a foreign citizen. In that situation, diversity jurisdiction is unavailable altogether.

Thus, under either of her own descriptions of her status, diversity jurisdiction could not be established.

4. Net Result: No Independent Basis for Federal Jurisdiction

Because:

the FAA does not itself create jurisdiction,
no valid federal claim existed against New York Life, and
no diversity jurisdiction could be satisfied under § 1332,

the district court correctly dismissed the FAA petition as to New York Life for lack of subject‑matter jurisdiction.

V. Simplifying Key Legal Concepts

A. Sovereign Immunity

What it is: A doctrine that the government (federal or state) cannot be sued unless it has clearly agreed to be sued by statute.

Practical effect in this case: Even if one believes a federal agency like the SEC has acted unlawfully or violated constitutional rights, one cannot sue for damages unless Congress has passed a law explicitly allowing that exact kind of lawsuit against that agency. No such law covered Tanjutco’s claims against the SEC.

B. Arbitral Immunity

What it is: A form of judicial‑type immunity for arbitrators and arbitration forums, shielding them from being sued for how they conduct arbitrations. It parallels the absolute immunity judges enjoy for acts taken in their judicial capacity.

Why it exists: To ensure arbitrators can decide cases independently and confidently, without fear of retaliatory lawsuits from disappointed parties.

Application here: FINRA could not be sued for damages over its handling of the arbitration or the content of the award.

C. SRO Immunity (FINRA’s Regulatory Immunity)

What it is: Because FINRA acts as a quasi‑governmental regulator in the securities industry (delegated authority from the SEC), it receives absolute immunity for its regulatory activities, such as:

investigations and disciplinary proceedings,
rulemaking and enforcement,
maintaining and publicizing regulatory records (CRD/BrokerCheck).

Effect: Individuals cannot obtain damages from FINRA for these regulatory acts, even if they believe the information is incorrect or injures their reputation.

D. Subject‑Matter Jurisdiction

What it is: The authority of a court to hear a specific type of case. Federal courts are courts of limited jurisdiction; they can only hear:

federal question cases – involving claims under the U.S. Constitution or federal law, or
diversity cases – disputes between citizens of different states (or between a U.S. citizen and a foreign citizen), with certain monetary thresholds.

Relevance here: The FAA does not expand this jurisdiction. Petitions to confirm or vacate arbitration awards must still fit into either federal question or diversity jurisdiction. If they do not, federal courts cannot hear them.

E. “Color of State Law” / State Action

What it is: A requirement that, for most constitutional claims against a defendant (like due process claims), the defendant’s conduct must be attributable to the government (state or federal). Purely private conduct typically does not trigger constitutional protections.

Application: Since New York Life is a private entity and there was no allegation it was acting on behalf of the government or in concert with government officials, Tanjutco’s constitutional claims could not be brought against it in federal court.

F. Domicile, Residence, and “Stateless” U.S. Citizens

Domicile: A person’s true, fixed, and permanent home – where they intend to remain or return to. It is more than temporary residence.

For diversity jurisdiction:

U.S. citizens are citizens of the U.S. state where they are domiciled.
U.S. citizens domiciled abroad are not considered citizens of any U.S. state, nor are they “foreign citizens.” They are “stateless” for § 1332 purposes and cannot be parties in diversity jurisdiction cases.

This unusual but settled rule meant that if Tanjutco was domiciled abroad in the Philippines, she could not rely on diversity jurisdiction at all.

VI. Impact and Practical Implications

A. For Litigants Challenging FINRA Arbitrations

Tanjutco reinforces a post‑Badgerow reality: federal courts are frequently unavailable venues for challenges to FINRA arbitration awards, particularly when:

the underlying dispute is grounded in state law (e.g., employment, contract, defamation), and
the parties are not completely diverse, or one party is a U.S. citizen domiciled abroad.

Parties and practitioners must:

Assess carefully whether there is a genuine federal cause of action on the face of any FAA petition.
Confirm complete diversity and citizenship facts at the time of filing.
Be prepared to proceed in state courts, which generally have concurrent jurisdiction over FAA petitions unless preempted by other statutes.

B. For Attempts to Sue FINRA or the SEC Over BrokerCheck Disclosures

The case illustrates the near‑impenetrable shield against damages liability in this area:

FINRA is absolutely immune in damages for regulatory disclosures like BrokerCheck entries.
The SEC is protected by sovereign immunity absent a specific statutory waiver authorizing suits of this type.

This leaves affected individuals with limited options, usually confined to internal FINRA expungement procedures, state‑law expungement/defamation strategies directed at employers (if available), or tightly constrained administrative/judicial review pathways that must be carefully invoked.

C. Clarifying the Post‑Badgerow Landscape

Tanjutco, following White Oak, continues a trend of strictly applying Badgerow in the Second Circuit. The message is clear:

FAA petitions under §§ 9 and 10 stand or fall on their own jurisdictional legs; courts will not “look through” to the underlying case to find federal jurisdiction.
Mere references to the Constitution, interstate commerce, or federal regulatory structures are not enough; there must be a cognizable federal cause of action or valid diversity on the face of the petition.

This can be especially surprising to pro se litigants who assume that because the arbitration involved federal securities regulations or took place under an SRO overseen by the SEC, a federal forum must be available. That assumption is no longer sustainable.

D. Significance for U.S. Citizens Living Abroad

The reaffirmation of Herrick is significant: U.S. citizens domiciled abroad cannot invoke federal diversity jurisdiction. This can be counter‑intuitive to dual nationals or expatriates who assume that “diversity” covers them as if they were foreign citizens.

In practice, they must usually litigate in:

state courts (where jurisdictional rules are different), or
foreign courts, depending on the location of parties and conduct.

E. Limits of Pro Se Liberal Construction

Although the Second Circuit reiterated its commitment to construing pro se filings liberally, the case shows the limits of that doctrine:

Liberal construction cannot create jurisdiction where none exists.
It cannot overcome sovereign, arbitral, or regulatory immunity.
It cannot rewrite the petition to invent a viable federal claim where the underlying facts and legal framework do not support one.

Courts will help pro se litigants articulate potentially valid claims, but they cannot disregard jurisdictional prerequisites or immunity doctrines.

VII. Conclusion

The Second Circuit’s summary order in Tanjutco v. NYLife Securities LLC may not be precedential, but it is a concise and instructive application of several hard‑edged rules that often surprise litigants:

Sovereign immunity bars damages suits against the SEC absent a clear statutory waiver, even when plaintiffs assert constitutional violations in connection with securities regulation and SRO oversight.
FINRA’s dual immunity – as an arbitration forum and as an SRO exercising delegated regulatory authority – forecloses private damages actions for alleged harms arising from arbitrations and BrokerCheck/CRD disclosures.
The FAA is not jurisdictional. Petitions to confirm or vacate arbitration awards must independently satisfy federal question or diversity jurisdiction on the face of the petition; courts cannot “look through” to the underlying dispute under Badgerow.
Constitutional claims require state action. Naming a private party like New York Life and invoking “due process” does not create a federal question where no state (or federal) action is properly alleged.
Diversity jurisdiction is constrained. U.S. citizens domiciled abroad are “stateless” for § 1332 and cannot invoke diversity, and there is no diversity where both sides are citizens of the same state.

Together, these points reinforce the structural limits on federal court power and the robust immunities that shield key institutional actors in the securities and arbitration systems. For practitioners and parties – particularly those proceeding pro se – Tanjutco serves as a cautionary example: significant disputes over FINRA arbitrations and regulatory disclosures will often have to be pursued, if at all, through narrowly defined regulatory procedures or state‑court remedies, not in federal damages actions against the SEC, FINRA, or private employers.

Jurisdictional and Immunity Barriers to Challenging FINRA Arbitrations and BrokerCheck Disclosures: Commentary on Tanjutco v. NYLife Securities LLC (2d Cir. Dec. 9, 2025)