BROWSE BY TOPIC
- Investments - Strategies
- Investments - Unsuitable
- Wall Street News
- Investor Protection
- Compliance Concepts
- Bad Brokers
- Investments - Private
- Rules & Regulations
- Bad Advisors
- Boiler Rooms
- Terminations/Cost Cutting
- General News
- Donald Trump & Co.
- Big Banks
- Regulatory Sanctions
Stories of Interest
- Sarah ten Siethoff is New Associate Director of SEC Investment Management Rulemaking Office
- Catherine Keating Appointed CEO of BNY Mellon Wealth Management
- Credit Suisse to Pay $47Mn to Resolve DOJ Asia Probe
- SEC Chair Clayton Goes 'Hat in Hand' Before Congress on 2019 Budget Request
- SEC's Opening Remarks to the Elder Justice Coordinating Council
- Massachusetts Jury Convicts CA Attorney of Securities Fraud
- Deutsche Bank Says 3 Senior Investment Bankers to Leave Firm
- World’s Biggest Hedge Fund Reportedly ‘Bearish On Financial Assets’
- SEC Fines Constant Contact, Popular Email Marketer, for Overstating Subscriber Numbers
- SocGen Agrees to Pay $1.3 Billion to End Libya, Libor Probes
- Cryptocurrency Exchange Bitfinex Briefly Halts Trading After Cyber Attack
- SEC Names Valerie Szczepanik Senior Advisor for Digital Assets and Innovation
- SEC Modernizes Delivery of Fund Reports, Seeks Public Feedback on Improving Fund Disclosure
- NYSE Says SEC Plan to Limit Exchange Rebates Would Hurt Investors
- Deutsche Bank faces another challenge with Fed stress test
- Former JPMorgan Broker Files racial discrimination suit against company
- $3.3Mn Winning Bid for Lunch with Warren Buffett
- Julie Erhardt is SEC's New Acting Chief Risk Officer
- Chyhe Becker is SEC's New Acting Chief Economist, Acting Director of Economic and Risk Analysis Division
- Getting a Handle on Virtual Currencies - FINRA
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
Non-Registered Employee Barred for Undisclosed Private Securities Transactions
by Howard Haykin
Emma Levin consented to be barred from the industry to settle FINRA charges that she participated in private securities transactions by recommending and facilitating the sale of limited partnership interests in a real-estate investment fund without providing prior notice to her member firm.
BACKGROUND. Levin, a resident of East Brunswick, NJ, was an NRF (Non-Registered Fingerprint) person associated with Goldman Sachs from October 2013 through September 2016. She had worked in the firm’s technology division.
FINRA FINDINGS. FINRA’s case against Ms. Levin addressed 3 distinct issues.
Issue #1. In August 2014 and July 2015, Levin participated in private securities transactions by recommending and facilitating the sale of limited partnership interests in the JPH Fund, a real-estate investment fund, to 2 investors for total proceeds of around $30,000. Before participating in these transactions, Levin failed to provide written notice to, or obtain prior written approval from, Goldman Sachs.
Issue #2. In February 2015 and February 2016, Ms. Levin compounded the situation by providing inaccurate responses on the Firm's annual attestations – i.e., Annual Compliance Questionnaires - concerning her participation in private securities transactions. Specifically, she falsely represented on the attestations that she had no "private investments or outside interests" and failed to disclose her participation in the JPH Fund.
Issue #3. From January 2015 through September 21, 2016 (the date of her termination), Ms. Levin assisted the JPH Fund in its material misrepresentations. While the JPH Fund had less than $200,000 in total assets under management during this period, she arranged for the Fund's website to include the following material misrepresentations – both of which were false:
- "We currently manage over $47 million of our clients' assets"; and,
- “We project to invest $75 million in real estate mortgages for 2015, which will earn our Investors $4.5 million in interest combined."
Among other things, these activities violated NASD Rule 3040 (replaced by FINRA Rule 3280), “Private Securities Transactions of an Associated Person.”
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 #2016051548501.