2021071714201 Spartan Capital Securities LLC CRD 146251_John Dennis Lowry CRD 4336146_Kim Marie Monchik CRD 2528972 Complaint ks.pdf

The Department of Enforcement alleges: 1. From April through July 2021 (the Relevant Period), Respondents Spartan Capital Securities LLC (Spartan), its Chief Executive Officer (CEO) John Dennis Lowry (Lowry), and its then-Chief Compliance Officer (CCO) Kim Marie Monchik (Monchik), engaged in a scheme to defraud firm customers who owned restricted shares of a pharmaceutical issuer that they wished to sell shortly after the company’s initial public offering (IPO) underwritten by Spartan. 2.

2023078062701 The Ultima Global Markets (USA), Inc., fka BCS Global Markets CRD 47895 AWC vrp.pdf

From at least August 2021 through September 2024, Ultima failed to establish and implement an anti-money laundering (AML) program that could be reasonably expected to detect and cause the reporting of potentially suspicious activity relating to low-priced securities transactions in correspondent accounts controlled by the firm’s affiliated FFIs, who traded on behalf of undisclosed customers. As a result, Ultima violated FINRA Rules 3310(a), 3310(f)(ii), and 2010.

Will Murphy Comment On Regulatory Notice 26-06

A. Forum Selection

A(i) Customer Disputes

A(i).1. Should certain categories of claims (e.g., of a certain complexity or value) or customer dispute types (e.g., those involving institutional customers or holders of institutional accounts) be subject to different requirements under FINRA rules?

a. Should certain categories of claims or customer dispute types be subject to different procedural requirements under FINRA rules? What customer protection and fairness considerations should be evaluated?

Will Murphy Comment On Regulatory Notice 26-06

For complex or unusually large claims, perhaps parties should be able to request a selection of arbitrators that all have had at least three cases go to an award after a final hearing.

If all parties have agreed to take FINRA arbitration off the table, I see no reason they should not be able to enforce such an agreement.

I see no reason to take any class of disputes out of FINRA arbitration.

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