How Difficult Can That Be?  LPL Financial agreed to settle FINRA's alleged charges that its Boston office did not properly supervise public appearances of its registered reps.  It's an interesting case because the firm already had written procedures in place for public appearances and had authorized the representative's actions.

Hitting the Airwaves.   In advance of a live radio broadcast, a representative of the firm submitted a request to conduct a live call-in finance and investment radio show in Farsi.  LPL approved the request on the condition that written procedures regarding public appearances be followed - which included, among other things:

• The first three radio shows be submitted to the firm's advertising compliance office upon airing.
• The advertising compliance office request randomly-chosen shows from representatives on a quarterly basis.
• Submission of foreign-language appearances must be translated by an unaffiliated third-party translation company.

What Went Wrong?   After receiving approval, the representative and another rep aired approximately 520 radio shows over 5 years on one radio station in a live call-in format in Farsi.  Despite previously arranging the reviews, sign-offs and translations, the firm apparently never requested nor reviewed copies or transcripts of the broadcasts. 

For the lack of oversight, LPL was fined $25,000 by FINRA in addition to the censure. [FINRA Case #2010021545201]