FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
FINRA publishes this quarterly review to provide firms with a sampling of recent disciplinary actions involving misconduct by registered representatives. The sample includes settled matters and decisions in litigated cases (National Adjudicatory Council decisions and decisions of the SEC in FINRA cases).
FINRA has taken disciplinary actions against the following firms and individuals for violations of FINRA rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
Exemptive relief is granted based on the determination that the dealer: (1) had developed and instituted procedures reasonably designed to ensure compliance with the rule; (2) had no actual knowledge of the contribution prior to or at the time of the contribution; (3) had taken all available steps to cause the person involved in making the contribution to obtain a return of the contribution; and (4) had taken such other remedial or preventative measures as were appropriate under the circumstances.
It appears that the violation of the Rule, as described in your letter, relates directly to the failure of the firm to develop and institute procedures reasonably designed to ensure compliance of the Rule i.e., for the review and approval of political contributions by a municipal finance professional prior to making the contribution. Accordingly, the firm's request for an exemption is denied.
The request for exemptive relief is denied. You represent that Firm had established comprehensive and detailed procedures which included the requirement to pre-clear political contributions. Indeed, the firm’s procedures were attached to your exemption request as "Attachment No. 2," and they require that "all public finance employees" of the firm obtain prior approval of political contributions. The CEO did not follow the firm’s established procedures. This lapse by a senior official is significant and leads us to conclude that the request for an exemption should be denied.
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Proposed Hire’s Contribution made more than one year ago; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Contribution mitigates the probability that the payment will improperly influence issuer officials; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.