On April 23, 2021, in Ford v. TD Ameritrade Holding Corp., 1 a panel of the U.S. Court of Appeals for the Eighth Circuit reversed a district court order certifying a class action alleging that TD Ameritrade committed securities fraud by failing to comply with the duty of best execution in executing customer orders. The decision deals a blow to securities class actions based on violations of a broker’s best execution obligation and highlights the difficulties investors face in certifying securities fraud claims outside a typical disclosure-based stock-drop case. Background The duty of best execution requires a broker-dealer to seek for its customer’s trade orders “the most favorable terms reasonably available under the circumstances.”