UT-based Intermountain Financial Services and a Registered Principal who's been with the firm since 1995, settled FINRA charges that they failed to enforce its WSP's pertaining to its annual compliance meeting, branch office inspections, outside business activities, outside securities accounts, Regulation SP, hiring practices and the use of personal computers, among other things.  Sanctions:  firm will pay $12,500;  Principal will pay $12,750, and be suspended 5 days as principal.  [C-I Note:  Sanctions seem light, given breadth of their failures - though we don't have all the facts.]

The firm, acting through Registered Principal Kent Sweat, allegedly:

1.  Failed to maintain copies of RRs' incoming and outgoing correspondence with the public re: its securities business.

2.  Failed to evidence correspondence reviews, as required by NASD rules and firm procedures.

3.  Failed to maintain records pertaining to its Firm Element CEP:  (i) Needs Analysis and Written Training Plan for multiple years;  (ii) Evidence that firm RR's participated in the Firm Element CEP during one year.

4.  Failed to implement procedures concerning the capturing, preservation, maintenance and storage of all original and copied communications the firm received and sent.

5. Failed to retain all electronic communications relating to its business. 

6.  Failed to implement a written AML compliance program reasonably designed to achieve the firm’s compliance with the laws, rules and regs. 

7.  Failed to provide AML training in a manner specified in its written AML program.

8.  Failed to properly update its AML compliance officer contact information as required.  

[FINRA Case #2008011579401, October]