1. Unlicensed Prop Trader Permitted to Exceed Trading Limits.
2. Third-Party Vendor Purged Virtually All Firm E-Comm.
3. Firm Failed to Evidence E-Comm Supervisory Reviews.
4. Firm Initiated Material Change in Business, Then Applied to FINRA.
5.     [ September Disciplinary Actions ]

    1. Unlicensed Prop Trader to Exceed Trading Limits.   NJ-based Assent LLC will pay $79K fine to settle charges it permitted a then-prop trader/associated person to engage in prop firm options trading when he was not properly licensed to do so - firm’s WSP's required prop trader to hold the Series 7, Series 55 and Series 63 licenses, and his activities should have been restricted until the licensing deficiency was rectified.  Failure to register this person violated NASD Rule 1032, as well.

In addition, firm allowed associated person to exceed his individual trading limits on several occasions, and failed to take adequate steps to ensure the associated person and others understood the meaning and application of the terms of the associated person’s individual trading limits.   (FINRA Case #2007008882402)

    2. Third-Party Vendor Purged Virtually All Firm E-Comm.   NJ-based Coady Diemar Partners, LLC will pay $35K fine and ordered to have CEO certify to FINRA on quality of firm's compliance practices re:  preservation of email communications.  Firm allegedly failed to maintain and preserve all of its business-related electronic communications.  Firm had engaged 3rd-party vendor to preserve such communications, but the vendor didn't properly retain them and ultimately purged virtually all of the e-communications it had initially captured for the firm.  And, the firm did not otherwise preserve all of its business-related e-comm and emails - apparently relying fully on vendor.  (FINRA Case #2008011683801)

    3. Firm Failed to Evidence E-Comm Supervisory Reviews.   TX-based First London Securities will pay $20K fine to settle charges it failed to establish and maintain a system to retain all e-communications, including emails, relating to its securities business for at least 3 years.  Firm used a 3rd-party vendor that only retained the firm’s e-communications for 45 days.  Finally, firm failed to provide FINRA with proof (evidence) that supervisory reviews of e-communications were conducted.  (FINRA Case #2008011589801)

    4. Firm Initiated Material Change in Business, Then Applied to FINRA.   CT-based Euro Pacific Capital, Inc., will pay $15K fine to settle charges it failed to obtain FINRA’s approval before initiating increases in sales personnel - a material change in its business operations.  By the time the an application was filed, it had exceeded the safe harbors for 5 months.  Further, during the application process, before FINRA rendered its decision on firm’s proposed expansion, it continued to add sales personnel until FINRA alerted the firm to its failure to comply with NASD Rule 1017. (FINRA Case #2008015429401)