FINRA’s October 2021 Disciplinary Actions

Firms Fined

Dough LLC (CRD #148243, Chicago, Illinois)

An AWC was issued and the Firm was censured and fined $10,000, neither admitting nor denying FINRA’s findings. FINRA discovered the Firm allowed an unregistered individual to operate as a principal and identify as the CEO. The unregistered individual held decision making responsibilities involving employee status and compensation and took part in the Firm’s securities business. (FINRA Case #2021069517501)

Maxim Group LLC (CRD #120709)

An AWC was issued and the Firm was censured, fined $65,000 and ordered to pay $422.63 in restitution. Without admitting nor denying FINRA’s findings, the Firm was trading for its own account at prices that would have satisfied outstanding customer orders. It was also found that the Firm’s order management system did not protect orders that the Firm accepted, held and routed away for execution. Therefore, the Firm failed to protect customers’ orders as it should have.  (FINRA Case #2019062082601)

Individuals Barred

James Francis O’Reilly

O’Reilly was barred from association with FINRA members in all capacities, refusing to appear for on-the-record testimony that was requested by FINRA. FINRA’s investigation gathered information involving O’Reilly’s potential involvement in undisclosed OBA and private securities transactions involving private placement offerings. (FINRA Case #2019064977701)

Walter Morrow Allen

Morrow was barred from association with FINRA members in all capacities. FINRA found that Allen’s former member Firm had filed his Form U5 for failing to garner written consent prior to executing trades in non-discretionary customer accounts. Allen was also found to have violated the Firm’s policies and procedures.   (FINRA Case #2020066785901)

Individuals Suspended

Henry Bones II

Bones was fined $5,000, suspended from any FINRA member Firm in any principal capacity for two months and required to attend and satisfactorily complete 20 hours of continuing education regarding supervisory responsibilities. FINRA found that Bones failed to reasonably supervise a former Registered Representative that was excessively trading in customers’ accounts. Bones ignored multiple red flags, taking no meaningful action to stop the misconduct that resulted in a realized loss of $415,626.  (FINRA Case #2017056432604)

Eneida Vega Cortes

An AWC was issued and Vega Cortes was fined $5,000 and suspended from association with any FINRA member Firm for 20 business days. Vega Cortes was found to have added instructions and the date to a letter of authorization previously signed by another employee, effecting the transfer of securities from the Firm’s trust department brokerage account to a client’s trust account. It was also found that Vega Cortes effected the transfers on four occasions, with both the Firm and customer authorizing the transactions. Through these transfers, Vega caused the Firm to maintain inaccurate books and records. (FINRA Case #2020065347506)

Jonathan Hurd, CAMS

CEO, COMPLIANCE AND RISK MANAGEMENT

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SEC ANNOUNCES ACTIONS AGAINST BROKER DEALERS AND INVESTMENT ADVISORY FIRMS CHARGING DEFICIENT CYBERSECURITY PROCEDURES