On November 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a member firm regarding its alleged failure to establish, maintain and enforce a supervisory system and written supervisory procedures (WSPs) to ensure compliance with rules governing registered persons’ outside business activities. Specifically, from December 2020 to November 2021, the firm allegedly evaluated or recorded the outside business activities inadequately of one of its registered representatives, who was managing an investment fund providing loans to early-stage companies. FINRA determined these constituted violations of NASD Rule 3110(b) and FINRA Rules 3270 and 2010. The firm consented to a censure and a $60,000 fine without admitting or denying the allegations and agreed to update its Form BD (Uniform Application for Broker-Dealer Registration).
