A Registered Rep from St. Louis, MO, accepted rather harsh disciplinary action to settle FINRA charges she participated in private securities transactions without notifying her member firm or obtaining its prior written approval.  This RR first became employed in the securities industry as an RR in April 2002.  Since that time, she has been registered with 3 successive FINRA member firms and currently is currently associated with a FINRA member firm. From March 2009 through March 2010, Kathryn Ann Winter participated in private securities transactions without providing prior written notice to her employer member firm - so as to describe in detail the proposed transactions and her proposed role therein, and to state whether she has received or may receive selling cornpensation in connection with the transactions. She went on to solicit investments from 3 customers of her member firm on behalf of Distinctive Properties (UK) Limited.  Those 3 customers subsequently invested $750,000 - one invested $500,000, and the other two invested $125,000 each.  Their invested funds were pooled in a common enterprise with the expectation of profits derived from the efforts of others. FINRA further concluded that Ms. Winter solicited these 3 customers without having reasonable grounds for believing that the recommendations were suitable for such customers, based upon the facts disclosed by such customers as to their securities holdings, and financial situation and needs.

[C-I Note: FINRA doesn't provide a lot of information about Distinctive Properties or about the 3 investors.  What we know is that they were customers of the firm - which would indicate that Ms. Winter should have had ample information from New Account Records, along with conversations with the individuals to enable her to determine suitability.  That is not explained.

What's also not explained or clear is the fact that, over the course of one full year, Ms. Winter only solicited 3 customers - and each agreed to invest.  Might this mean that Ms. Winter did not have a large book of business and thus applied a heavy sales pitch to these 3 customers?  DK.

Lastly, if these customers were comfortable with the investment and their dealings with Ms. Winter, why did they not submit affidavits to FINRA supporting Ms. Winter?  That could have eliminated one of FINRA's two charges, and thus significantly eased her sanctions.  Just some thoughts as to how Ms. Winter have have better defended herself.]

FINRA Sanctions. Ms. Winter accepted a $12.5K fine and a 180-day suspension (OUCH!!!).   [Disciplinary Actions for October 2011] For further details, go to:   [FINRA AWC #2011026378701]