Securities representative suspended and fined for allegedly instructing an assistant to complete firm-required online compliance training on his behalf
FINRA Rule 2010
Products representative suspended and fined for allegedly failing to timely disclose felony charges on form U4
FINRA Rule 1122
FINRA Rule 2010
FINRA By-Laws Article V, Section 2
Former securities representative suspended and fined for allegedly forging customer signatures
The representative electronically signed the names of two customers on an insurance application without their permission. Although the application remained unsubmitted, one of the customers complained.
In addition the representative requested that six customers sign blank forms that were then completed on their behalf by the representative. None of these customers complained.
FINRA Rule 2010
FINRA Rule 4511
Securities representative suspended and fined for allegedly engaging in an outside business activity without notice to or authorization
FINRA Rule 2010
FINRA Rule 3270
Former associated person barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Arlington Securities censured and fined, and its securities principal suspended and fined for alleged suitability requirements shortcomings
The firm’s supervisory system and WSPs were not reasonably designed to supervise the suitability of recommendation by representatives relating to mutual funds and variable annuities.
They failed to describe the steps that supervisors must take to review the suitability of such transactions, including the identification of red flags and whether there was a reasonable basis to believe that:
- the customer had been informed of the various features of the annuity;
- the customer would benefit from key features of the annuity;
- the annuity was suitable for the particular customer based on their investment profile.
The firm also failed to reasonably review the suitability of the securities principal’s recommendations to customers to liquidate their mutual funds in order to purchase higher-cost variable annuities.
The securities principal, who was also president, CEO and CFO of the firm, recommended the liquidation of mutual funds and the purchase of an investment-only variable annuity to 14 customers.
The principal did not have a reasonable basis to believe that the customers would benefit from the features of the recommended annuity and had no reasonable basis on which to conclude that his recommendations were suitable.
The firm and principal have also consented to a joint and several restitutionary payment of $67,026.47 plus interest.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 6730
Union Capital Company censured for alleged Reg BI failings connected to non-traditional funds
The firm failed to establish and maintain a supervisory system reasonably designed to ensure compliance with Reg BI obligations with respect to non-traditional funds.
The firm’s WSPs did not:
- include specific policies or procedures for the supervision of these funds;
- state whether representatives were able to recommend the funds;
- specify under what circumstances the products should or should not be recommended;
- provide any guidance to supervisors on how to identify or address potentially unsuitable recommendations;
- provide any training to representatives or supervisors regarding the terms, features and risks of the funds.
A restitutionary payment of $28,237.85 has been ordered and the firm has agreed to an undertaking requiring it to certify in writing the remediation of the issues identified.
FINRA Rule 2010
FINRA Rule 2111
FINRA Rule 2330
FINRA Rule 3110
Former securities representative and trader suspended and fined for allegedly participating in the creation of non-contemporaneous branch inspection reports
In March 2023 the representative prepared branch inspection reports purported for the years 2020 and 2021. These reports were then signed and back-dated by the firm’s CCO.
FINRA Rule 2010
FINRA Rule 4511
Securities representative suspended and fined for allegedly excessively trading in a customer account
A restitutionary payment of $19,275 plus interest has been ordered.
FINRA Rule 2010
FINRA Rule 2111
Former securities representative suspended and fined for alleged Reg BI violations
The representative did not have a reasonable basis to believe that the investment strategy that she recommended to two firm customers was in their best interest.
FINRA Rule 2010 FINRA Notice to Members 04-89 SEA 1934 Rule 15l-1 SEC Reg BI
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |