Three disciplinary actions hinged on financial and net capital violations by FINRA member firms.  Here are their unique stories.

    1.  Barclays Capital Inc. (New York, NY) agreed to pay $60K to settle FINRA charges it allegedly failed to reconcile its various balance sheets and ledgers.  Although the accounting errors were large, most were overstatements of credits and/or understatements of debits - none of which resulted in a net capital deficiency, though one resulted in a customer reserve account hindsight deficiency.  A recurring error caused Barclays not to treat an affiliate account as a customer account - which resulted in another customer reserve account hindsight deficiency.   (FINRA Case #2009017479101)

    2.  First American Capital and Trading Corp. (Boca Raton, FL) agreed to pay $22.5K to settle FINRA charges it allegedly failed to maintain its minimum net capital requirement when it erroneously carried short sales in U.S. Treasury bonds, totaling $100 million in its proprietary account instead of executing a long position of $50,000,000 and a short position of $50,000,000.  This resulted in a net deficiency of $.6 million.  On top of that, firm allegedly failed to make, keep and preserve the order tickets for the bond transactions that led to the net capital deficiency.  Further, by apparently not monitoring the trading limits of its fixed income traders, the U.S. Treasury bond transaction posting error went undetected and uncorrected.  (FINRA Case #2007009194301)

    3.  Peraza Capital and Investment, LLC (St. Petersburg, FL) agreed to pay $12.5K to settle FINRA charges it allegedly failed to maintain its minimum net capital requirement, which resulted from the following firm failures:  (i) to record expenses on its books and records;  (ii) to accrue commissions payable;  (iii) to classify securities and cash in a brokerage account the firm maintained as nonallowable assets;  (iv) to classify a debit balance in the brokerage account, maintained as non-allowable assets, as a liability;  and/or (v) to correctly calculate haircuts.  Further, the firm placed more than 10 prop trades in 2008, which had the effect of raising its minimum net capital requirement - yet, the the firm didn't file, and didn't timely file, the requisite notification of its net capital deficiencies.  (FINRA Case #2008011713901)