FINRA charged the FinOp and CCO of a Wakefield, MA, broker-dealer, who also was the firm AML officer, with failing to fulfill his responsibilities to file complete and accurate quarterly FOCUS Reports and complete and accurate CRD submissions for all associates of the firm. Paul Lysan Industry Background. Lysan first became registered as a Series 7 in 1987;  in 1991, he became registered as a FinOp.  In 1997, Lysan became licensed as a Series 24, General Securities Principal.  Lysan also is registered with the state of Massachusetts as an investment adviser.  Between 1987 and the present, Lysan has been registered at 10 FINRA member firms.  [C-I  Note: Would that indicate he's a rent-a-finop?  It's just not clear.]  In addition, Lysan is a CPA and sells fixed insurance products. Since 2004, Lysan has been registered with FINRA through an association with a member firm where he is a GSR, GSP and investment adviser.  Also beginning in 2004, Lysan became registered through another member firm where he is a part-time FINOP.  From November 2008 through July 2010, the time period relevant to this action, Lysan also was registered with FINRA through an association with former member firm Trade Desk Financial Corp.  Lysan initially was TDFC's FinOp. Starting 1/20/09, he also assumed the additional roles of CCO and AML compliance officer (AMLCO). FOCUS Filings. As FINOP and CCO, Paul Lysan knew, or should have known, that the firm was trading for its own account and that, as a result, its financial books and records should have reflected this net capital requirement.  Securities Exchange Act Rule 15c3-l(a)(2)(iii)(B) requires a broker-dealer that effects more than ten (10)  transactions in one calendar year for its own accounts to maintain a minimum of $100,000 in net capital. By at least as early as 2/18/09, TDFC had effected more than 10 transactions for its own account in 2009.  And the firm continued to trade for its account, at least through 5/29/09.  May 29, 2009.  et, none of the firm’s quarterly FOCUS Reports for a calendar year accurately reflected the firm’s net capital, excess net capital, minimum required net capital or proprietary inventory.  Instead, Lysan reported the firm as a $5K broker-dealer. Bookkeeping Services. Throughout the time Lysan was associated with the firm, the firm used the bookkeeping services of an officer of the firm and one of its owners.  However, Lysan, who was responsible for supervising the officer’s activities as bookkeeper at the firm and was responsible for ensuring that personnel at the firm were appropriately fingerprinted when required by SEC rules, never fingerprinted the officer nor submitted fingerprints on her behalf. Throughout the officer’s association with the firm, she worked from her home, where she maintained original financial books and records for the firm.  Lysan knew, or should have known, he was required to take fingerprints and submit them to the SEC, pursuant to Securities Exchange Act Rule 17f-2. FINRA Sanctions. For his alleged failings, Paul Lysan agreed to a $7.5K fine and 10-day suspension. For further details, go to:  [FINRA AWC #2009016452501] and [FINRA Disciplinary Actions for March 2012].