FINRA disciplinary action update 2024/34

Disciplinary decisions issued August 24 – 30, 2024.

Bananafina LLC expelled for allegedly failing to provide documents and information

The firm has been expelled from the FINRA funding portal membership.

FINRA Rule 8210
FINRA Funding Portal Rule 200
FINRA Funding Portal Rule 800

Owner of firm suspended and fined for allegedly making false statements

FINRA Funding Portal Rule 100
FINRA Funding Portal Rule 200

Product representative suspended and fined for allegedly falsely certifying that she had personally completed the continuing education required to hold an insurance license

Another person had completed 15 hours of insurance continuing education on her behalf.

FINRA Rule 2010

Former products representative barred for allegedly failing to produce information and documents

FINRA Rule 2010
FINRA Rule 8210

BBVA Securities censured and fined for allegedly failing to use the NR indicator where required by TRACE reporting rules

The firm does not review TRACE reports for accuracy and its reliance on the review of order information, rejection notices and other information cannot detect errors such as the failure to include the No Remuneration indicator.

The firm has agreed to the imposition of an undertaking requiring it to certify in writing the remediation of the issues identified.

FINRA Rule 2010
FINRA Rule 3110

Merrill Lynch censured and fined for alleged supervisory system failures connected to potentially manipulative trading

The parameters in the firm’s automated surveillance system were too narrow to effectively identify potentially manipulative wash trading and prearranged trading.

The firm did not take reasonable steps to determine and ensure that these parameters were reasonable and effective.

The firm also:

  • failed to have a surveillance system in place to detect manipulative trading in OTC securities because it had not purchased the relevant data feed from its vendor;
  • did not include wash trading in warrants in its surveillance modules because of a coding error;
  • failed to review alerts generated by three of its wash trading and prearranged trading surveillance patters in equities and options.

The firm has agreed to the imposition of an undertaking requiring it to certify in writing the remediation of the issues identified.

FINRA Rule 2010
FINRA Rule 3110

Former securities representative barred for allegedly refusing to appear for on-the-record testimony

FINRA Rule 2010
FINRA Rule 8210

Former securities principal suspended and fined for allegedly excessively trading in a customer’s account

The principal recommended high frequency in-and-out trading even when the price of the recommended securities did not materially change.

A restitutionary payment of $43,495.37 plus interest has been ordered.


FINRA Rule 2010
FINRA Rule 2111

Securities representative suspended and fined for alleged excessive trading in customer accounts

The excessive trading also constituted a violation of the general obligation of Reg BI.

And the representative exercised discretionary power in customer accounts without obtaining the required authorization.

A restitutionary payment of $115,000 has also been ordered.


FINRA Rule 2010
FINRA Rule 2111
FINRA Rule 3260
SEA 1934 Rule 15l-1
SEC Reg BI

Place Trade Financial censured and fined for allegedly making exaggerated and misleading statements on its website

Examples of exaggerated, misleading or promissory statements included those:

  • that did not describe how the claimed conclusions were reached;
  • were based on outdated data which did not provide a sound basis for customer evaluation of the service;
  • that exaggerated the size and experience of the teams at the firm;
  • that improperly promised positive investment returns regardless of market conditions, clients’ available resources or clients’ time horizons.
FINRA Rule 2010
FINRA Rule 2210

Raymond James & Associates censured and fined for allegedly failing to supervise the reporting of customer complaints

The firm failed to disclose customer complaints in a timely manner, with the disclosures between 2018 and 2021 being, on average, three years late.

In many instances the firm failed to promptly:

  1. research complaints;
  2. transmit them to supervisors;
  3. transmit them to staff responsible for determining their reportability;
  4. relay determinations about their reportability to staff responsible for making Form U4 and U5 amendments.

The firm also failed to reasonably supervise direct mutual fund transactions because an inadvertently applied data filter blocked these from being ingested by its automated surveillance system.

FINRA By-Laws Article V Section 2
FINRA By-Laws Article V Section 3
FINRA Rule 1122
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 4530
NASD Rule 3010

Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them.