Former products representative barred for allegedly refusing to provide information and documents
FINRA Rule 2010
FINRA Rule 8210
Thurston Springer Financial censured and fined for alleged Reg BI and other compliance shortcomings
The firm failed to establish, maintain and enforce a supervisory system reasonably designed to ensure compliance with Reg BI. The firm’s WSPs discussed Reg BI in general terms only without establishing any procedures for achieving compliance with the rule.
The WSPs did not:
- describe the steps registered representatives should take to ensure their recommendations are in the customers’ best interest;
- explain how firm supervisors should review recommendations for compliance including assessing both costs and alternatives; and
- contain specific provisions regarding disclosure of potential conflicts of interest to retail customers.
The firm’s WSPs did not cover the procedures required to ensure compliance with its Form CRS obligations including:
- delivering the form to customers;
- updating the form; and
- creating and maintaining records related to the form.
No supervisor was tasked with responsibility for the firm’s compliance with Form CRS rules.
In addition the firm also failed to:
- have in place a system reasonably designed to review electronic communications;
- update some Forms UR in response to civil litigation involving allegations of sales practice violations;
- put in place a system reasonably designed to review transactions in outside brokerage accounts held by its associated persons;
- conduct the office inspections required by FINRA rules; and
- conduct supervisory control testing including providing annual reports to senior management detailing the controls in place at the firm.
The firm has agreed to an undertaking requiring it to certify in writing the remediation of the issues identified including a review of firm emails between March 31, 2023 and October 24, 2024.
FINRA Rule 1122
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 3120
FINRA Rule 3130
FINRA Rule 4530
SEA 1934 Rule 15l-1
SEC Reg BI
Securities representative suspended for allegedly making unsuitable trading recommendations
The level of trading was excessive and not in the best interest of the customers.
FINRA Rule 2010
FINRA Rule 2111
Revere Securities censured and fined for allegedly mismarking trade tickets
Order tickets in syndicate offerings were marked as unsolicited irrespective of whether the transactions were recommended to customers by a representative.
FINRA Rule 2010
FINRA Rule 4511
SEA 1934 Rule 17a-3
Former securities representative suspended and fined for allegedly borrowing funds from a customer
FINRA Rule 2010
FINRA Rule 3240
Financial Northeastern censured and fined for allegedly failing to report transactions in TRACE-eligible securities in a timely fashion
The reporting issues occurred despite the firm having previously received two written warnings about the late-reporting of TRACE-eligible transactions.
FINRA Rule 2010
FINRA Rule 6730
TRACE
Liberty Partners Financial Services censured and fined for alleged Reg BI failings
The firm failed to establish, maintain and enforce written policies and procedures reasonably designed to ensure compliance with its Reg BI obligations connected to non-traditional ETP recommendations to retail customers.
The firm also misclassified some fees it was schedule to receive from mutual fund issuers as allowable assets. The fees were owed to firm representatives.
As a result the firm:
- failed to make and preserve accurate books and records;
- filed inaccurate FOCUS reports; and
- conducted a securities business while failing to maintain the require minimum net capital.
In addition the firm also failed to conduct an independent test of its AML compliance program between 2020 and 2023.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 3310
FINRA Rule 4110
FINRA Reg Notice 09-31
FINRA Reg Notice 12-03
SEA 1934 Rule 15l-1
SEA 1934 Rule 15c3-1
SEC Reg BI
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
