Isaak Bond Investments censured and fined for allegedly conducting a securities business while failing to maintain its minimum required net capital
The firm also filed to make and preserve accurate records of its net capital, filed inaccurate FOCUS reports and untimely financial deficiency notices.
In addition the firm failed to obtain the requisite annual independent test of its AML program.
FINRA Rule 2010
FINRA Rule 3310
FINRA Rule 4110
FINRA Rule 4511
SEA 1934 Rule 17a-3
SEA 1934 Rule 17a-5
SEA 1934 Rule 17a-11
SEA 1934 Rule 15c3-1
Investment Placement Group censured and fined for alleged recordkeeping failures
The firm permitted employees to use an electronic messaging platform provided by a vendor.
In order for the messages sent and received by the employees to be captured their personal devices had to be connected to the archiving service.
The firm, however, did not take reasonable steps to ensure that this happened. And some employees authorized to use the messaging platform were never actually connected to the archiving service, while others were only connected for a portion of the time.
As a result an unknown number of business-related messages were never preserved or reviewed by the firm, which meant that the firm failed to comply with its recordkeeping obligations.
The firm has also agreed to an imposition of an undertaking requiring it to certify in writing the remediation of the issues identified.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 4511
SEA 1934 Rule 17a-4
Cantor Fitzgerald censured and fined for allegedly filing untimely or inaccurate notifications
The firm failed to:
- file timely notices of intent prior to engaging in syndicate covering transactions;
- submit timely and accurate restricted period notifications; and
- submit timely and accurate trading notifications.
In practice the firm also did not conduct reviews of its Regulation M-related notifications to ensure that these were submitted accurately and in a timely fashion. And its supervisory system and WSPs were not reasonably designed to ensure compliance with its notification obligations.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 5190
Regulation M Rule 104
Securities representative suspended and fined for allegedly mismarking positions in order to conceal unrealized losses
The representative entered into six forward start reverse repurchase positions.
Subsequently he mismarked the positions in an effort to make it appear that these were more profitable than they actually were and continued to do so for 3-4 months, thereby concealing unrealized losses of over $15m.
FINRA Rule 2010
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
