FINRA disciplinary action update 2024/13

Disciplinary decisions issued March 30 – April 5, 2024.

Former securities representative barred for allegedly refusing to produce information and documents

FINRA Rule 2010
FINRA Rule 8210

Former securities representative barred for allegedly refusing to provide information and documents

FINRA Rule 2010
FINRA Rule 8210

Securities representative suspended and fined for allegedly falsely certifying that she had personally completed the continuing education required to hold an insurance license

Another person had completed 15 hours of insurance continuing education on her behalf.

FINRA Rule 2010

Former securities representative barred for allegedly refusing to appear for on-the-record testimony

FINRA Rule 2010
FINRA Rule 8210

Cobra Trading censured and fined for alleged compliance failings connected to social media communications

The firm paid 17 influencers a referral fee for any business that stemmed from their social media posts made on the firm’s behalf. The posts created by the influencers were not fair or balanced and contained promissory language. The posts also failed to disclose the they were advertisements.

The firm did not have a system in place to supervise the retail communications posted by the influencers.

In addition the firm failed to approve the videos posted by influencers and did not preserve these.

The firm has agreed to the imposition of an undertaking requiring it to certify in writing the remediation of the compliance issues identified.

SEA 1934 Rule 17a-4(b)(4)
FINRA Rule 2010
FINRA Rule 2210
FINRA Rule 3110
FINRA Rule 4511
FINRA Regulatory Notice 10-06
FINRA Regulatory Notice 17-18

Former products representative suspended and fined for allegedly falsifying the electronic signatures of customers

19 documents were electronically signed by the representative with the prior permission of nine customers.

FINRA Rule 2010
FINRA Rule 4511

Former securities representative suspended and fined for alleged contraventions of Reg BI

The representative recommended a series of transactions to a customer that were excessive in light of their investment profile.

FINRA Rule 2010
SEA 1934 15l-1

Products representative suspended and fined for allegedly falsely certifying that he had personally completed the continuing education required to hold an insurance license

Another person had completed 15 hours of insurance continuing education on his behalf.

FINRA Rule 2010

Dawson James Securities censured and fined for alleged business communications and private placement compliance lapses

The firm did not capture, retain or review over 10,900 business-related text messages sent or received by at least 27 associated persons.

The firm’s management were aware of the practice and its CEO, Robert Dawson Keyser Jr., sent or received approximately 4,400 text messages himself. These were also not retained by the firm and Keyser Jr. has also been suspended and fined as part of this AWC.

The firm also failed to conduct reasonable due diligence of private placement offerings. The firm did not maintain a record of any due diligence that it conducted on follow-on offerings or in connection with the solicitation of customers.

The firm has agreed to an undertaking requiring it to retain a third party consultant to review the adequacy of its supervisory system, policies, procedures and internal controls and to produce a written report on its findings to FINRA. The firm will be required to adopt and implement the recommendations made as part of the report within 30 days of its delivery.

This AWC is covered in more detail in this GRIP article.

FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 4511
FINRA Regulatory Notice 10-22
FINRA Regulatory Notice 23-08
NASD Rule 3110
SEA 1934 Rule 17a-4

Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them.