Patrick Capital Markets censured and fined for allegedly failing to terminate two private placement offerings following a material change to the terms
The firm was required to terminate two of the contingency offerings and return investor funds, but instead continued to raise funds for both offerings.
A third offering did not reach the required minimum contingency amount, but the firm prematurely released investor funds to the issuer. This meant that the representation that investor funds would be returned if a minimum amount was not raised was false.
FINRA Rule 2010
SEA 1934 Rule 10b-9
Former product representative suspended and fined for allegedly failing to disclose an outside business activity
FINRA Rule 2010
FINRA Rule 3270
Former securities representative barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Former securities principal barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Investment banking representative suspended and fined for allegedly participating in private securities transactions without notice to or authorization from his firm
FINRA Rule 2010
FINRA Rule 3280
BOK Financial Securities censured and fined for alleged inaccurate TRACE reporting
The firm did not include the required NR indicator when reporting securities and securitized product transactions.
Although the firm’s supervisory system included reviews of TRACE reporting, this did not involve evaluating the NR indicator, despite this being entered manually.
The system was therefore not reasonably designed to ensure the accuracy of the TRACE reports.
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 3110
FINRA Regulatory Notice 09-31
FINRA Regulatory Notice 12-03
SEA 1934 Rule 15l-1
SEC Reg BI
LifeSci Capital censured and fined for alleged compliance failings connected to public offerings
In connection with an initial public offering the firm received underwriting compensation that was both unfair and unreasonable.
The firm inaccurately described its underwriting compensation in its offering documents and its FINRA filings and also failed to make the required filings with FINRA.
In addition the firm did not have in place a supervisory system reasonably designed to ensure adherence to rules governing the underwriting of public securities and the fairness of its underwriting compensation.
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
FINRA Rule 5110
NASD Rule 3010
Securities representative suspended and fined for allegedly failing to disclose an outside business activity
FINRA Rule 2010
FINRA Rule 3270
SG Americas Securities censured and fined for allegedly failing to comply with fingerprinting requirements
The firm failed to:
- fingerprint non-registered associated persons;
- to make and keep current required fingerprint records;
- establish a supervisory system reasonably designed to ensure compliance with fingerprinting requirements.
The firm has agreed to the imposition of an undertaking requiring it to certify in writing the completion of review, implementation and remediation efforts connected to the fingerprinting of non-registered associated persons.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 4511
SEA 1934 Rule 17a-3
SEC Rule 17a-3
SEC Rule 17f-2
Former securities representative suspended and fined for allegedly maintaining outside brokerage accounts without notice to or authorization from his firm
FINRA Rule 2010
FINRA Rule 3210
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
