Registered Principal Vincent Bruno of Middletown, NJ, agreed to a $10K fine and a 1-month suspension to settle FINRA charges that, as his member firm’s Chief Compliance Officer, he failed to ensure that the firm established, maintained and enforced a supervisory system and WSPs reasonably designed to achieve compliance with private offering solicitations.  FINRA alleges that the firm's supervisory system and WSPs as they related to private offering solicitations were deficient, in that they didn't specify:

• who at the firm was responsible for performing due diligence;
• what activities firm personnel were required to do in order to satisfy due diligence;
• how due diligence was to be documented;
• who at the firm was responsible for reviewing and approving what due diligence was conducted;
• who at the firm was responsible for authorizing the sale of the securities;
• who was to perform ongoing supervision of the private offerings once customer solicitations commenced.

It's finally alleged that, as a result of its deficient WSPs, the firm failed to conduct adequate due diligence on private placement offerings, and Bruno failed to take any other steps to otherwise ensure that it was conducted.   This is FINRA Case #2009018771701.   [FINRA Disciplinary Actions Reported for March 2011]