FINRA to UBS Financial Services (Weehawken, NJ):  "What we have, here, is a failure to communicate."  Perhaps FINRA didn't use those exact words - taken from Cool Hand Luke, the movie, but it conveys a significant resason for UBS's alleged registration violations.  The firm agreed to pay a $200K fine and conduct a comprehensive review of its supervisory procedures, among other things, to settle FINRA charges it permitted employees to function as principals and RR's without the requisite registration. 

    Communications Gap.   While UBS's registration tracking materials apparently identified which individuals needed qualification examinations, the firm allegedly failed to follow through in making its associated persons obtain the requisite registrations. 

FINRA cited several alleged deficiences:  (i) WSPs and supervisory system didn't clearly assign respective registration responsibilities between Compliance personnel and business unit supervisors, which resulted in "communication gaps" between the departments;  (ii) Compliance was not consistent in notifying supervisors about registration issues;  (iii) firm procedures didn't provide reasonable guidance as to specific steps needed to be taken when an individual was hired or given new responsibilities affecting their registration status;  (iv) procedures didn't require that employees be given specific deadlines for testing and other actions;  (v) procedures didn't provide for reasonable follow-up and review to ensure compliance;  and, (vi) representatives were sometimes permitted to delay taking required exams. 

Scope of the Comprehensive Systems Review.   Following a comprehensive review and testing of its supervisory system and procedures concerning compliance with rules and regs relating to registration of principals and representatives in its home office, UBS must submit within 120 days a written report detailing its review, findings, testing and recommendations.  UBS then has 90 days to implement those recommended system and procedural changes, and thereafter certify in writing to FINRA that all these steps were completed. 

This is FINRA Case #2009017976301, as reported in:  [FINRA Disciplinary Actions for January].