FINRA disciplinary action update 2024/35

Disciplinary decisions issued September 7 – 13, 2024.

Securities representative suspended and fined for allegedly falsifying customer signatures

None of the customers complained and the transactions were authorized.

FINRA Rule 2010

JP Morgan censured and fined for allegedly permitting unregistered individuals to perform investment banking activities

A total of 10 individuals carried out investment banking activities requiring registration after becoming employed by the bank, but before being registered with FINRA. The period between their employment and registration ranged from 68 to 196 days.

The firm’s supervisory system was not reasonably designed to ensure compliance with registration requirements. The email reminders sent to individuals and their supervisors were not escalated by the system and there were no controls to prevent unregistered individuals from being added to investment banking teams or access systems.

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

Securities representative suspended and fined for allegedly using WeChat to communicate about securities business

The firm was not an communications method or social media platform approved by the firm in question.

FINRA Rule 2010
FINRA Rule 4511

Former securities representative charged with allegedly failing to appear for on-the-record testimony

This is a complaint and not an AWC.

FINRA Rule 2010
FINRA Rule 8210

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

FINRA Rule 2010
FINRA Rule 8210

Former products principal suspended and fined for allegedly forging customer signatures

12 customer names on 15 representative of record change request forms were signed manually and without permission as part of transitioning the customers from a prior to a new firm.

FINRA Rule 2010
FINRA Rule 4511

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

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

FINRA Rule 2010

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


FINRA Rule 1122
FINRA Rule 2010

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

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


FINRA Rule 2010

Former associate suspended and fined for allegedly failing to disclose a felony charge


FINRA Rule 1122
FINRA Rule 2010

Wells Fargo Clearing Services censured and fined for allegedly failing to supervise retail customer recommendations for short-term trading of stocks and funds

The firm relied on an electronic system to identify short-term trading in syndicate preferred stock, closed-end funds (CEFs) and medium-term notes (MTNs).

The system generated daily alerts for liquidations within 90 days of purchase, but not for those that occurred 90 days after purchase.

A representative recommended short-term trades of preferred stock that were held for 180 days or less and sold at a loss, but the automatic surveillance system did not detect or flag these transactions.

When the short-term trades were flagged by the system the firm notified the representative, but failed to reasonably follow up and address the red flags indicative of unsuitable trading.

Eventually the representative received a warning email from the firm, but this only led to him ceasing recommending short-term trading in MTNs. He continued to recommend trading both preferred stocks and CEFs on a short term basis.

In addition the firm did not establish and maintain a supervisory system reasonably designed to achieve compliance with suitability obligations for its substantial syndicate preferred stock and CEFs business.

A restitutionary payment of $599,025.29 along with a disgorgement of $2,031,972.10 has been ordered.

FINRA Rule 2010
FINRA Rule 3110

Securities representative suspended and fined for allegedly fabricating an email

The representative attempted to conceal the fact that the firm had failed to submit a signed redemption request form to a product issuer within the required redemption window.

FINRA Rule 2010

Securities Research censured and fined for alleged supervision and Reg BI failings

The firm failed to effectively supervise short-term mutual fund switching. The firm:

  • failed to describe the steps that supervisors should take when conducting monthly reviews of such switches in its written procedures;
  • failed to establish a system reasonably designed to determine whether such short-term switches were in the customers’ best interest;
  • did not use tools offered by its clearing firm that would have been a reasonable alternative to its own systems and processes;
  • relied on a manual review of a deficient monthly report of mutual fund transactions by supervisors;
  • did not include detailed steps representatives were to take to identify and assess reasonably available alternatives when recommending mutual fund switches.

The deficiencies resulted in a registered representative recommending and effecting 25 short-term switches that were neither suitable nor in the best interest of two senior customers.

In addition the firm failed to reasonably supervise mutual fund exchange privileges and the rights-of-reinstatement due to customers. This resulted in excess sales charges and fees relating to 39 mutual fund exchanges in 11 customer accounts.

A restitutionary payment of $49,253.72 has been ordered.

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

FINRA Rule 2010
FINRA Rule 2111
FINRA Rule 3110
SEA 1934 Rule 15l-1
SEC Reg BI

Securities Principal suspended and fined for allegedly failing to respond to red flags of excessive trading escalated to him

Members of the principals team escalated a number of red flags suggesting excessive trading by a registered representative.

Despite the escalations from lower level supervisors the principal did not review the series of trades that the registered representative was placing.

The registered representative did indeed excessively trade in five customer accounts.

FINRA Rule 2010
FINRA Rule 3110

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