Searle & Co. of  Greenwich, CT, and its Managing Principal agreed to accept FINRA charges related to the firm's private placement activity.   The firm ("SCO"), a retail broker-dealer since 1983, is engaged in, among other things, the sale of stocks, municipal and corporate bonds and private offerings. Registered Principal Robert Searle ("Searle"), President and CCO of SCO, holds registrations as an Introducing Broker-Dealer FinOP, a Series 7 Rep, and a Series 24 General Securities Principal.  Neither the firm nor Searle had prior relevant disciplinary history. FINRA Allegations Re: Placement Business. Acting through Searle, the firm failed to adequately supervise its placement business.  FINRA found that:

• A former RR conducted the placement business out of an unregistered office.
• Firm sought and received permission to conduct its private placement activity, but didn't identify this business on Form BD until years later.
• This caused the firm to file inaccurate FOCUS Reports and inaccurate annual audits.
• Firm failed to adequately ensure that its ledgers or other records accurately reflected all of the firm’s assets, liabilities, income and expenses.
• Firm impermissibly “netted” the commission revenue it received, failing to reflect the gross amount of commission the firm received and the amount paid to the RR who placed the business - which understated gross revenues and expenses.

Other Alleged Violations and Deficiencies. From 2006 through mid-2008, firm failed to adequately supervise the use of outside emails for firm business - i.e., it permitted associated persons to use personal email accounts to send and receive emails related to firm’s securities business without capturing, reviewing or retaining them. Between February 2004 and April 2008, firm paid fees and commissions totaling $21 million to 4 non-registered LLC entities of which the firm’s RRs were the sole members.  Moreover, firm improperly paid the non-registered entities rather than paying the commissions and fees directly to the RRs who owned the non-registered entities. Sanctions. Robert Searle received a 10-day suspension as principal;  Searle & Co. was fined $47.5K , of which $10K is joint and several with Mr. Searle.  For further details, go to:   [FINRA AWC #2009016262101]  [Disciplinary Actions for Sept 2011]