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Regulatory Sanctions

Better Late Than Never in this FINRA Examination

November 13, 2017

by Howard Haykin


In September 2017, FINRA reported that 10 brokers were barred from the industry for either: (i) refusing to appear for FINRA on-the-record testimony; or, (ii) refusing to respond to FINRA’s requests for documents and information. So, how did the broker in this case avoid being barred?


Munaem Choudhury agreed to pay a $5K fine and serve a 6-month suspension to settle FINRA charges that he failed to timely respond to FINRA requests for documents and information in connection with an ongoing examination involving him during his association with his member firm. 


BACKGROUND.    Choudhury (aka Maurice Skiles), a resident of Ridgewood, NY, has 15 years’ experience with 12 firms.  He was associated with Chelsea Financial Services as a General Securities Representative and a General Securities Principal (Series 24) from June 2012 until July 2015. His suspension is currently in effect.


FINRA FINDINGS.    Choudhury failed to respond to FINRA requests for documents and information:


  • FINRA Staff sent letters to Choudhury on 3/14/16, 4/4/16, and 4/14/16, requesting documents and information in connection with an ongoing examination involving Choudhury during his association with Chelsea.


  • Choudhury provided a partial response on 5/11/16.


  • FINRA Staff requested a complete response to all outstanding requests on 5/17/17.


  • Choudhury did not respond to FINRA’s latest request.


  • FINRA Enforcement initiated a non-summary suspension proceeding against Choudhury on 8/16/16.


  • Choudhury finally responded in full to the document and information requests, between 9/7/16 and 11/30/16.


FINANCIALISH TAKE AWAYS.    Choudhury wasn't a model broker - he worked for 12 broker-dealers over 15 years, and he amassed 10 disclosures on his CRD. So, I wasn't sympathetic to his case when I read how Choudhury pushed aside request after request from FINRA for documents and information. I even wondered why he hadn't been barred from the industry.


But, Choudhury finally took the high road and began giving FINRA what it wanted - just 6 months late. And maybe it's a coincidence that FINRA issued a 6-month suspension.


So, what are we to conclude from this case?

►  You'll pay a price when "TAKING YOUR SWEET TIME" to respond to a FINRA inquiry.

►  A full and complete response to FINRA is “BETTER LATE THAN NEVER.”


This case was reported in FINRA Disciplinary Actions for September 2017.

For details on this case, go to ...  FINRA Disciplinary Actions Online, and refer to Case #2016049602302.