Great Nation Investment Corporation of Amarillo, TX, agreed to a $10K fine to settle FINRA charges related to a “minimum-maximum” bond offering it underwrote.  Here are FINRA's findings and allegations against Great Nation:

Background.  According to the prospectus of the issuing entity, the offering would raise a minimum of $99,000 and a maximum of $2,500,000, and that:  (i) investor funds would be deposited in an interest-bearing escrow account with an escrow agent until the minimum offering amount was raised;  (ii) if the minimum offering amount was not raised during the offering period, all funds would be returned to investors.  And, in connection with the offering, Great Nation entered into an escrow agreement with a bank that did business as the escrow agent. 

What Went Wrong.   In  contravention of SEC Rule 15c2-4, the escrow agreement provided, among other things, that the escrow agent should hold the escrow property in trust, commingled with similar funds of other issuers.  Furthermore ...

• Upon receipt of funds from the offering, the escrow agent deposited the funds into an account at an unaffiliated third-party bank that was not a party to the escrow agreement.  It was here that investor funds from the offering were commingled with investment funds from several other unrelated offerings for which it served as escrow agent.
• Great Nation failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules.
• The firm's WSP's were deficient in that they did not have provisions re: establishing and monitoring escrow accounts in connection with contingent securities offerings.
• In contravention with terms of the prospectus, firm accepted checks for the offering, totaling over $100,000, which were made payable to the firm instead of to the escrow agent.
• The firm willfully violated Section 15(c) of the Securities Exchange Act of 1934, SEC Rule 15c2-4 and NASD Rule 2110.

This is FINRA Case #2008011602901.  [May 2011 Disciplinary Actions]