1. RR Put Customers On Edge of Cliff with 'Stock to Cash' Program.
2. Principal "Quietly Settled" Customer Complaint;  Paid Ultimate Price.
3. Placement Agent's Alleged Mishandling of Contingent Offering.
4. Fargo's Supervision Couldn't Prevent Missed Complaint Filing.
   
5. [FiNRA Disciplinary Actions for December]

• failed to sufficiently determine whether his clients’ ownership interest in the pledged securities was adequately protected.
• didn't understand the risks inherent in the strategy and therefore lacked a reasonable basis for his recommendations.
• engaged in private securities transactions through his marketing of the program, but didn't notify the firm or get its prior approval.
• was directed by his supervisor to disclose his participation in the program to the firm, yet didn't do so until the day of his supervisor’s annual branch exam; 
• continued to recommend the program to customers even while the firm was reviewing his participation. 
• was told by the firm’s sales practice unit that he wasn't allowed to recommend Stock to Cash transactions.   (FINRA Case #2007008935001)

    2.  Principal "Quietly Settled" Customer Complaint;  Paid the Ultimate Price.   FL-based Reg'd Principal Markowitz agreed to be barred from the industry, to settle FINRA charges he effected transactions in a customer’s account without the customer’s prior knowledge, authorization or consent.  In response to a customer's verbal complaint to Markowitz about the amount of commissions charged in her account, Markowitz allegedly gave her a $1,500 check to settle the complaint.  [Of course] Markowitz never told his firm about the customer’s complaint or his payment.   (FINRA Case #2009021131201)

    3.  Placement Agent's Alleged Mishandling of Contingent Offering.   TX-based broker-dealer Premier Group agreed to a $12.5K fine, to settle FINRA charges it acted as the sole placement agent for contingent offerings and failed to ensure proper control of investors’ funds by sending such funds directly to the issuer.  Furthermore, Premier allegedly: 

• neglected to promptly transmit customers’ checks.
• failed to meet the minimum contingency by a contingent offering’s termination date;
• failed to break escrow for a contingent offering until after the termination date;
• failed to amend the offering and failed to offer each investor rescission or reconfirmation to continue with the offering - in willful violation of SEC Rule 17a-3(a)(2) and NASD Rule 2110;
• failed to book liabilities associated with its expense sharing agreement;
• failed to enter into an adequate expense sharing agreement with its affiliate;  and,
• failed to properly accrue liabilities, so it was operating in net capital deficiency.  (FINRA Case #2008011618101)

    4.  Fargo's Supervision Couldn't Prevent Missed Complaint Filing.   The firm's St.Louis-based Advisors Financial Network agreed to a $15K fine, to settle FINRA charges it failed to file summary and statistical information for customer complaints by the 15th day of the month following the calendar quarter in which the firm received them.  FINRA also blames WF's supervisory system, saying it failed to ensure the filing, failed to provide for reasonable follow-up and review.  [C-I: Even the big boys and girls get clipped.]   (FINRA Case #2009016286401)