Robin Fran Bush, as the CCO for Newbridge Securities, was responsible for creating, maintaining and updating her firm’s WSPs and for conducting due diligence for private offerings.  Newbridge approved for sale, and sold, various private offerings. The following are FINRA's findings:

For One Such Offering ... Bush's due diligence consisted of reviewing the PPM and investor subscription documents.  She did not, however: (i) seek or obtain financial documents or information from the issuer re: the offering;  (ii) obtain any due diligence report;  (iii) visit the issuer’s facilities or meet with its key personnel;  (iv) take steps to ensure, or otherwise verify, that other firm principals were conducting any due diligence of the offering’s issuer.  The firm and Ms. Bush eventually obtained a 3rd-party due diligence report, but did so after firm customers had already invested in the offering.

For a Third Private Offering ... Bush conducted due diligence after the product had been sold to customers.  Her due diligence consisted of obtaining investor subscription documents without obtaining PPMs for the offerings.  She did not obtain any due diligence report from an independent 3rd party;  nor did she meet with any executives to understand the nature of the offerings.

For Additional, Different Unregistered Offerings ... Bush, acting as CCO and the designed principal for private offerings, failed to conduct due diligence for each of these other offerings. 

Moreover, FINRA found that the firm’s supervisory system and WSP's for private offerings - that Bush had drafted and maintained - were deficient, in that they did not identify, in any detail, specific due diligence steps to be taken for private offerings or identify specific documents to be obtained for private offerings the firm was contemplating selling.  The WSP's for private offering due diligence were conclusory, non-specific and lacking in the requisite minimum detail regarding steps to be taken and firm personnel responsible for such steps.

Ms. Bush was fined $15,000 and suspended as principal for 6 months.   This is FINRA Case #2009016159402.   [Disciplinary Action for May 2011]