BROWSE BY TOPIC
Stories of Interest
- Canada's CIBC Completes $5Bn PrivateBancorp Buy
- Word ‘Women’ Literally Never Appears in U.S. Senate’s 142-Page Health-Care Bill
- Stephen Pierce, Goldman Sachs Global Head of Equity Markets, To Retire
- Al Gore 'Not Very Smart,’ But Became Filthy Rich Using Simple Investing Formula - Charlie Munger
- U.S. Regulators, Lawmakers Support Volcker Rule Revamp at Hearing
- Morgan Stanley Opts for Frankfurt as New EU Hub
- A New Risk for Goldman, Morgan Stanley in Stress Tests (subsc reqd)
- A Trump Bump for Law Firm of President’s Lawyer - Kasowitz Benson Torres
- JPMorgan, BofA, Goldman, Citi, Wells Fargo Pass Fed's Stress Test
- Blackstone Stock Still Trading at $31 - Its IPO Price From 10 Years Ago
- NJ Resident and NY-Based Global FX Club Charged with Solicitation Fraud, Misappropriation - CFTC
- Senate Republicans Release Plan to Replace Obamacare - The Details
- Berkshire Hathaway Throws $1.5Bn Lifeline to Canada's Home Capital
- Inside Nomura: Day in the Life of a Junior Banker
- Inside Travis Kalanick’s Resignation as Uber’s C.E.O.
- Creative Planning, KS Investment Firm, Spurring Change on Wall Street
- SEC Obtains Judgment Against Attorney Who Defrauded Escrow Clients
- SEC Files Fraud Charges Against Stock Promoters in Market Manipulation Scheme
- Power Lunches and Dinners in New York, London, Washington
- Banks to Cut $1.2Bn in Research Spending, Analyst Jobs - McKinsey
We seek to provide information, insights and direction that may enable the Financial Community to effectively and efficiently operate in a regulatory risk-free environment by curating content from all over the web.
Stay Informed with the latest fanancialish news.
NEWSLETTERS & ALERTS
When a CCO Seems ‘In Over Her Head’ and FINRA Pays a Visit
by Howard Haykin
Melissa Strouse, a Chief Compliance Officer, agreed to a $10K fine, along with a 10-day suspension from serving as a principal, to settle FINRA charges that she failed to establish adequate WSPs for various supervisory functions, and that she failed to carry out her assigned supervisory responsibilities.
BACKGROUND. Strouse, who resides in Cave Creek, AZ, has been associated with First Financial Equity Corporation (FFEC) since March 1999. Ms. Strouse currently is registered as a general securities representative, a general securities principal, an options principal, and an operations professional. At all relevant times, Ms. Strouse was FFEC's Chief Compliance Officer (CCO).
FINRA FINDINGS. For the period, 1/1/10 through 6/23/13, FINRA cited FFEC for numerous supervisory deficiencies. And, since Ms. Strouse was the firm's CCO throughout that period, FINRA held her personally responsible. As CCO, Ms. Strouse not only was responsible for ensuring that the Firm's compliance and supervision systems operated effectively, by she had primary supervisory responsibility for the Firm's main OSJ in Scottsdale, AZ, where a significant number of the Firm's supervisory failures occurred. Furthermore, Ms. Strouse had oversight for discretionary accounts.
Among the deficiencies:
- FFEC's procedures for conducting heightened supervision of registered reps did not detail how surveillance reviews were to be conducted, the frequency of the reviews, and how the reviews were to be evidenced.
- From July 2012 through June 2013, FFEC’s procedures with respect to suitability requirements failed to ensure that requisite customer information was obtained before reps were permitted to recommend securities and/or investment strategies to firm customers.
- While FFEC recommended and sold ETFs - including leveraged and inverse ETFs - to its customers, FFEC did not have any written procedures for the supervision, approval, and sale of ETFs.
- FFEC's procedures for supervising and overseeing discretionary accounts were either not performed or evidenced in writing. Specifically, the designated supervisor was required to:
► Promptly approve, in writing, each order entered for discretionary accounts.
► Review discretionary accounts frequently to detect and prevent activity which may be excessive in size or frequency.
► Conduct monthly reviews of discretionary account statements for potential areas of concern – e.g., churning, excessive trading, suitability issues, or other unusual trading patterns.
FINANCIALISH TAKE-AWAYS. Ms. Strouse was overwhelmed by her responsibilities as Chief Compliance Officer. Perhaps the firm had dumped too many tasks on her - a common lament among CCOs. Or perhaps she wasn’t capable to wearing the many hats she was assigned to wear. And perhaps she never spoke up to call for help.
Whatever the case, FFEC’s supervisory issues were many and too many required procedures were not being performed. That said, it seems that Ms. Strouse got off relatively easy, in terms of sanctions.
As an update to this story, I visited the company web site and found that First Financial Equity Corporation has a new CCO – Randy Sitzman, who’s also the Scottsdale, AZ, Branch Manager. Good luck!
This case was reported in FINRA Disciplinary Actions for May 2017.
For details on this case, go to ... FINRA Disciplinary Actions Online, and refer to Case #2013034966701.