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Regulatory Sanctions

FINRA Priorities: Quarterly Disciplinary Review, October 2017

October 31, 2017

FINRA just published its quarterly review of recent disciplinary actions involving registered reps – as a complement to its monthly disciplinary actions report. This quarter, FINRA highlights the following categories:


  1. Executing an Inaccurately Dated and False Compliance and Supervisory Processes Certification
  2. Misplacing Customer Funds and Borrowing Funds from a Customer Without Prior Firm Approval 0 FINRA settled a matter
  3. Concealing the Receipt of Funds From a Customer, Using Text Messages to Communicate With Customers, and Recommending an Unsuitable Transaction to a Customer
  4. Participating in Private Securities Transactions, Making Unsuitable Recommendations, and Engaging in Undisclosed Outside Business Activities
  5. Serving as a Firm’s Chief Administrative Officer Without the Appropriate Registration
  6. Failing to Reasonably Supervise the Offer and Sale of Mortgage-Backed Securities
  7. Placing an Unauthorized Trade in a Customer’s Account


[Click link below for details for FINRA’s detailed discussion of each category.]


FINANCIALISH TAKE AWAYS.    Financialish wrote an article about the case covered in FINRA’s first category - "CCO May Have Cracked Under Pressure When He Failed Annual Certification Obligations,” published 6/2/17. In that case, FINRA AWC #2012033767402, FINRA reached a settlement with the respondent on 4/27/17 - the detailed of which differ from what FINRA reports in this quarterly review.


It's an interesting read, and addresses the options a Chief Compliance Officer faces when he or she is "stuck between a rock and a hard place."