[ by Howard Haykin ] FINRA flagged down BGC Financial, L.P., the New York-based broker, for taking the "cart ahead of the horse" - i.e., it permitted a disqualified individual to associate with the firm without regulatory approval. Profile of BGC Financial, L.P. A member of FINRA since 1987, the firm employs approximately 450 registered individuals who operate from 4 different locations.  BGC conducts a general securities business. FINRA Findings and Allegations. In brief, BGC permitted a disqualified individual to associate with it without regulatory approval.  BGC also failed to establish and maintain a supervisory system and establish, maintain and enforce WSPs effective enough to achieve compliance with applicable securities laws and regs with regard to the association of disqualified individuals with the firm. Such actions would violate NASD Conduct Rule 3010 and FINRA Rule 2010. Improper Employment of Disqualified Individual. In 1984, the SEC brought an action against an RR  in federal court through which he was permanently enjoined from violating the federal securities laws and ordered to disgorge profits for engaging in insider trading. In a related administrative action, also in 1984, the RR agreed to be barred from the industry - with the right to reapply - to settle the SEC charges. As such, this RR became subject to a disqualification with respect to associating with a member firm.  At various times from 1985 to 2009, the RR was able to obtain regulatory approval to associate with several different broker-dealers. On 9/30/09, BGC filed a Form U4 on the RR's behalf, seeking his registration as a General Securities Representative.  Around that time, the RR informed BGC that he was subject to disqualification with respect to associating with a member firm.  On 11/2/09, BGC filed a membership continuance application with FINRA seeking permission for DC to associate with it, but that application was never approved. Nevertheless, in October and November 2009, the RR allegedly engaged in the securities business of BGC, sitting on one of its trading desks and engaging in trading and brokerage activities.  Permitting a disqualified individual to associate with a broker-dealer without regulatory approval would violate FINRA Rule 2010. Supervisory Deficiencies. The above actions, in turn, prompted FINRA to charge that least June 2009 through December 2009, BGC failed to establish and maintain a supervisory system and establish, maintain and enforce WSPs reasonably designed to ensure compliance with applicable securities laws and regs. FINRA Sanctions. Obviously, the firm acted like a typical New Yorker, wanting to start operating when it saw fit.  Whether BGC "took the cart ahead of the horse," or "operated within a New York Minute" - it was too darn fast for FINRA, which ticketed BGC for $40K. For further details, go to:  [FINRA AWC #2009020627602] and [FINRA Disciplinary Actions for June, 2012].