Statements by SEC Chair and Commissioners on Rule 192
CFTC
FINRA
FINRA Censures and Fines Windmill Group for Excessive Commissions
In the Matter of The Windmill Group, Inc., Respondent (FINRA AWC)
FINRA Censures and Fines SoFi Securities LLC, M1 Finance LLC, Sogo Trade, Inc., and Open to the Public Investing, Inc. for Fully Paid Securities Lending Supervision
FINRA Fines and Suspends Rep for Discretionary Trading and Untimely U4 Disclosure
In the Matter of Matthew Mierzycki, Respondent (FINRA AWC)
FINRA Bars Rep for Unauthorized Series 7 Materials and Providing False Information
In the Matter of David Korsnack, Respondent (FINRA AWC)
FINRA Suspends Rep for Willful Untimely Disclosure of Felony Charges
In the Matter of Jacob David Frankel, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for Inaccurate Rep Code
In the Matter of Daniel H. Vatterott, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for Inaccurate Rep Code
In the Matter of Justin H. Parkhurst, Respondent (FINRA AWC)
FINRA Censures and Fines The Benchmark Company for Failing to Restrict Flow of Potentially Material Nonpublic Research Information
In the Matter of The Benchmark Company, LLC , Respondent (FINRA AWC)
FINRA Censures and Fines Actinver for Supervision of Pre-Arranged Trades
In the Matter of Altema Securities, Inc., formerly known as Actinver Securities, Inc., Respondent (FINRA AWC)
FINRA Censures and Fines TIAA-CREF for Customer Complaints Reporting
In the Matter of TIAA-CREF Individual & Institutional Services, LLC, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for Variable Annuities Recommendations
In the Matter of Malay Kumar, Respondent (FINRA AWC)
FINRA Fines BofA Securities $24 Million for Treasuries Spoofing and Related Supervisory Failures / Firm Engaged in 717 Instances of Spoofing Activity (FINRA Release)
FINRA Fines and Suspends Rep for Impersonations
In the Matter of John Patterson Corey, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for E-Commerce and Lead Generation OBAs
In the Matter of Ian James Prukner, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for E-Commerce and Lead Generation OBAs
In the Matter of Melton Weaver III, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for Electronic Signatures
In the Matter of Jacob Pae, Respondent (FINRA AWC )
FINRA Fines and Suspends Rep for Inaccurate Customer Information
In the Matter of Ronald Morse, Respondent (FINRA AWC)
FINRA Fines and Suspends Rep for Changed Rep Codes
In the Matter of Michael MacLean, Respondent (FINRA AWC)
FINRA Censures and Fines TD Private Client Wealth LLC for Supervision of Correspondence and Communications
In the Matter of TD Private Client Wealth LLC, Respondent (FINRA AWC)
FINRA Censures and Fines Cowen for NMS Reports and Supervision
In the Matter of Cowen and Company(in its own right and as successor-in-interest to Cowen Prime Services LLC), Respondent (FINRA AWC)
FINRA Arbitration Panel Grants Motion for Stipulated Award
In the Matter of the Arbitration Between NYLife Securities LLC and
New York Life Insurance Company, Claimants, v. James Myers, Respondent (FINRA Arbitration Award)
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SEC Sustains In Part And Remands FINRA Case Against Southeast Investments And President Black (BrokeAndBroker.com Blog)
https://www.brokeandbroker.com/7197/finra-sec-southeast-black/
Too often, the Decisions that emanate from FINRA's Office of Hearing Officers or NAC are conclusory and bereft of sufficient discussion and rationale as to justify the effort. In the case of the 2019 NAC Decision at issue here, that body discharged its role in superb fashion -- which in part may account for the SEC's ability to dissect and analyze FINRA's analysis and rationale underpinning its two decisions. What is too often lost when dealing with FINRA regulatory cases is that there is supposed to be a distinction between the role and conduct of the Enforcement staff prosecuting a case and the role and conduct of the OHO and NAC panelists adjudicating the case. In Southeastern, there is no question that the line of demarcation is wide between the prosecutors and adjudicators. Notwithstanding that the SEC has to some extent rebuked FINRA's Enforcement staff, that determination was to a large degree facilitated by the extensive record published by the NAC.
The Financial Professionals Coalition Needs Executive Recruiters
https://www.finprocoalition.com/news/1023/financialprofessionalscoalition-financial-professionals-coalition-executive-recruiters/
From the desk of Stephen Kohn, Founder and Chair of Financial Professionals Coalition (www.finprocoalition.com) and a 25-year veteran owner of a FINRA broker-dealer, a, former member of FINRA’s National Adjudicatory Council and a Former Governor on FINRA’s Board.
The Financial Professionals Coalition, Ltd. is a diverse resource for over 1.2 million registered representatives, associated persons, traders, bankers, back-office staff, and owners of broker-dealers and registered investment advisors. The Coalition provides courtesy consultations with industry experts. Membership is free.
As Covid winds down, many brokerage firms are forced to confront years of declining profits and a challenging economy. As is often the case, the industry is announcing layoffs and reductions-in-force. The Coalition notes an increasing number of calls from Compliance, Legal, Audit, Risk, Financial, and Operations staff seeking job placement or assistance with relocation. In response, we issue this call for Executive Recruiters to contact the Coalition and join our roster of resources. We need to refer many industry professionals and employers to reputable recruiters. If you and your company are prepared to offer your services to our Members, please contact us so that we can arrange for a listing of your contact information.
Also, the Coalition offers a cost-effective classified advertising Marketplace (https://www.finprocoalition.com/marketplace/) for the posting of Help Wanted (employer), Position Wanted (employee), Professional Services (lawyers, CPAs, and consultants), and Announcements. All placements are for an affordable flat fee and a 30-day-run.
For more information, please email sakohn@finprocoalition.com.
Small Firm Conference Fireside Chat - Missed Opportunity? (Financial Professionals Coalition by Chair Stephen Kohn)
https://www.finprocoalition.com/news/1022/smallfirmconference-small-firm-conference-fireside-chat-missed-opportunity/
Missed Opportunity: that's how the Financial Professionals Coalition's Chair Stephen Kohn summed up decades of FINRA Small Firm frustration with its self-regulator: Sadly, FINRA offers little more than chats and podcasts by way of addressing the industry's tailspin towards extinction. In part, Chair Kohn lamented that:
What I find most distressing is that regulation continues to drive its small member firms out of business, contrary to our regulators’ assessments. It would seem that both of these “Chats” would be a perfect forum to air some of the following factual, published information, and more, in an open and transparent way. Perhaps ideas for how to stop the bleeding may come from the small firm community itself, if anyone would stop to listen. The decline in membership is really simple math.
FINRA Refuses To Publish Board Election Vote Tallies -- Three Months Of Regulatory Hypocrisy (BrokeAndBroker.com Blog)
https://www.brokeandbroker.com/7205/finra-board-election/
FINRA's bedrock regulation is Rule 2010: STANDARDS OF COMMERCIAL HONOR AND PRINCIPLES OF TRADE: A member, in the conduct of its business, shall observe high standards of commercial honor and just and equitable principles of trade. What grotesque hypocrisy for this self-regulatory-organization with that core rule to pursue its indefensible course of conduct by not fully and timely disclosing the vote tallies of its Board elections. Three months ago, on September 6, 2023, FINRA declared the victories of two unopposed candidates in its Board of Governors elections; however, FINRA still declines to publish the tally of the votes cast for each candidate and, critically, fails to publish the tally of votes cast in "Abstention." FINRA's conduct seems more in the nature of a cover-up than the robust disclosure expected from a regulator: so much for high standards of corporate governance. Worse, no sitting FINRA Governor has spoken out against the organization's unacceptable failure to promptly disclose the actual votes in the 2023 election; but, in truth, such equivocation is all too characteristic of this lackluster Board. There is no honor in this ongoing cover-up. There is nothing just and equitable in holding an election but not disclosing the actual vote.
FINRA Takes A Shameful Victory Lap In Its Spoofing Settlement With Bank Of America (BrokeAndBroker.com Blog)
https://www.brokeandbroker.com/7204/finra-boa-awc-spoofing/
Oh my!!! It's another day and another press release from FINRA announcing one of the largest fines in the history of mankind and how yet another in a long line of messages has been sent to the industry about how the self-regulatory-organization will not tolerate this latest infraction. What we see here in this AWC is a failure of in-house compliance coupled with a failure of industry self-regulation. It's long past due for this failed experiment in FINRA self-regulation to be shut down and replaced.
Rarely do the wheels of justice spin quickly and smoothly. More often than not, it's a long, slow grind. By way of example, Oral Argument is scheduled today before the United States Supreme Court in Securities and Exchange Commission v. Jarkesy pursuant to the granting of certiorari on June 30, 2023 -- and the underlying SEC case goes back a decade to 2013, and the underlying misconduct goes back even more years. The core issue before SCOTUS today is whether the SEC is constitutionally and statutorily empowered to enforce the federal securities laws via its in-house administrative apparatus. LISTEN to or READ ORAL ARGUMENTS at link on website.
2Cir Affirms FINRA Arbitration Award to Respondent Schwab
In an Amended FINRA Arbitration Statement of Claim filed in January 2020, public customer Claimant Halperin asserted breach of contract; deceit, intentional misrepresentation and failure to disclose; untrue or misleading public statements; violation of California's Unfair Competition Law; negligence, violation of the Securities Exchange Act of 1934; and violation of FINRA Rules. In the Matter of the Arbitration Between Evan K. Halperin Revocable Living Trust, Claimant, v. Charles Schwab & Co., Inc., Respondent (FINRA Arbitration Award 19-03738)
https://www.finra.org/sites/default/files/aao_documents/19-03738.pdf The causes of action allegedly related to Claimant's online trading in options. Respondent Schwab generally denied the allegations and asserted various affirmative defenses. The FINRA Arbitration Panel denied Claimant's claims but found Claimant liable to and ordered payment to Respondent Schwab of $100,000 in attorneys fees and $42,750.22 in costs. OUCH!!! Thereafter, the Trust petitioned the United States District Court for the Southern District of New York to vacate the FINRA Arbitration Award, which denied the Petition and granted the cross-petition of Schwab to confirm the Award. On appeal to the United States Court of Appeals for the Second Circuit, the Trust argued that the SDNY was required to vacate the Award because the arbitrators had failed to compel certain Discovery by Schwab in purported violation of the Federal Arbitration Act ("FAA"). Evan K. Halperin Revocable Living Trust, Petitioner-Appellant, v. Charles Schwab & Co. Inc., Respondent-Appellee (Summary Order, United States Court of Appeals for the Second Circuit, 22-CV-2748 / November 29, 2023)
https://ww3.ca2.uscourts.gov/decisions/isysquery/b795aad6-912e-431f-a75f-b6444e203e8b/7/doc/22-2784_so.pdf In affirming SDNY, 2Cir found in part that:
Here, the Trust has failed to demonstrate that the Panel’s decisions with respect to discovery rendered the arbitration proceeding fundamentally unfair.2 To the contrary, after considering numerous discovery motions by the Trust to compel discovery (including hearing oral argument on some of these motions), the Panel directed Schwab to produce certain data and documents requested by the Trust. In total, Schwab produced over 5,500 documents to the Trust across 14 different document productions. The Panel also conducted an in-person arbitration hearing over five days, during which the Trust called three witnesses and presented evidence and arguments in support of its claim that the alleged interruptions on the Schwab internet platform caused its losses. Although the Trust argues that the arbitration proceeding was fundamentally unfair because of the Panel’s refusal to order Schwab to produce electronically stored information (“ESI”) pertaining to security systems that monitor and affect user sessions after login, we find that argument unpersuasive. The Panel required Schwab to produce a declaration “affirming that fraud parameter reports related to activity within a session do not exist.” App’x at 1114. Schwab produced the Declaration of Kostas Konstantinides, Schwab’s Director of Client Authorization, explaining that Schwab does not maintain certain reports for post log-in activities of users on the internet platform. The Trust then had a full and fair opportunity to be heard on the specific issue of whether the Panel should accept that declaration as compliant with the Panel’s order. For example, Kevin Baker, the Trust’s digital forensics expert, submitted a declaration opining that Schwab’s contention that it does not maintain a fraud detection system that records user activity after login was “inconceivable.” Id. at 1128. The Panel, after considering the evidence, rejected the Trust’s argument and held that Schwab complied with the Panel’s prior discovery order. Baker also testified at the arbitration hearing about the allegedly missing data. As the district court correctly noted in its thorough and well-reasoned decision, “[t]he Trust could have called Konstantinides as a witness at the Arbitration hearing to examine him on his knowledge of a so-called ‘fraud detection system’ and the existence of any In-Session Activity ESI, but failed to do so.” Evan K. Halperin Revocable Living Trust, 2022 WL 4334655, at *7. Thus, the discovery process and the hearing itself were more than sufficient to give the Trust “an adequate opportunity to present its evidence and argument.” Tempo Shain, 120 F.3d at 20 (internal quotation marks omitted).
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Footnote 2: Schwab contends that the Trust was required to demonstrate by clear and convincing evidence that the arbitration proceeding was fundamentally unfair under Section 10(a)(3). The Trust counters that, although we have applied that heightened standard to cases involving allegations of fraud or impartiality under Sections 10(a)(1) and (a)(2), respectively, the “clear and convincing” standard is not the proper burden of proof for its claim under Section 10(a)(3). In making this argument, however, the Trust concedes that, even without a heightened evidentiary standard for claims under Section 10(a)(3), it must meet the “heavy burden . . . [of] prov[ing] the arbitrators engaged in conduct that deprived it of a fundamentally fair hearing.” Appellant’s Reply at 9 (internal quotation marks and citation omitted). We need not address this issue here because, even assuming arguendo that the “clear and convincing” standard does not apply to the Trust’s claim under Section 10(a)(3), we conclude that the Trust has failed to meet its heavy burden of demonstrating that the arbitration proceeding was fundamentally unfair.
at Pages 4 - 5 of the 2Cir Order
CFPB Orders Bank of America to Pay $12 Million for Reporting False Mortgage Data / Loan officers routinely falsified forms about mortgage applicants (CFPB Release)
https://www.consumerfinance.gov/about-us/newsroom/cfpb-orders-bank-of-america-to-pay-12-million-for-reporting-false-mortgage-data/
The CFPB issued an Order https://www.consumerfinance.gov/enforcement/actions/bank-of-america-na-hmda-data-2023/ requiring that Bank of America, N.A. pay a $12 million penalty for submitting false mortgage lending information to the federal government. As alleged in part in the CFPB Release:
The Home Mortgage Disclosure Act requires financial institutions to report demographic data about mortgage applicants. The CFPB’s review of Bank of America’s HMDA data collection practices found that the bank was submitting false data, including falsely reporting that mortgage applicants were declining to answer demographic questions. This conduct violated HMDA and its implementing regulation, Regulation C, as well as the Consumer Financial Protection Act. Specifically, the CFPB found that Bank of America:
- Falsely reported that applicants declined to provide information: Hundreds of Bank of America loan officers reported that 100% of mortgage applicants chose not to provide their demographic data over at least a three month period. In fact, these loan officers were not asking applicants for demographic data, but instead were falsely recording that the applicants chose not to provide the information.
- Failed to adequately oversee accurate data collection: Bank of America did not ensure that its mortgage loan officers accurately collected and reported the demographic data required under HMDA. For example, the bank identified that many loan officers receiving applications by phone were failing to collect the required data as early as 2013, but the bank turned a blind eye for years despite knowledge of the problem.
The CFPB has taken numerous actions against Bank of America for violating federal law. In July 2023, the CFPB and the Office of the Comptroller of the Currency (OCC) ordered Bank of America to pay over $200 million for illegally charging junk fees, withholding credit card rewards, and opening fake accounts. In 2022, CFPB and OCC ordered Bank of America to pay $225 million in fines and refund hundreds of millions of dollars to consumers for botched disbursement of state unemployment benefits. That same year, Bank of America also paid a $10 million penalty for unlawful garnishments of customer accounts. And in 2014, the CFPB ordered Bank of America to pay $727 million to consumers for illegal and deceptive credit card marketing practices.
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DOJ
Real Estate Promoter Pleads Guilty To Defrauding Investors (DOJ Release)
https://www.justice.gov/usao-sdny/pr/real-estate-promoter-pleads-guilty-defrauding-investors
In the United States District Court for the Southern District of New York, Eliezer Tilson pled guilty to an Information charging him with one count of violating the Travel Act . As alleged in part in the DOJ Release:
In October 2019, TILSON solicited investments from two investors in New York City in an investment fund that focused on multifamily residential real estate projects. The two investors together sent $650,000 to TILSON for investment in the fund. TILSON never transmitted any of the victims' money to the fund. Instead, he used most of the money to pay dividends to other investors in separate, unrelated real estate projects and pay down prior debt incurred by other, unrelated entities.
When the victims first asked why their funds had not arrived at the investment fund, TILSON falsely assured them that the fund had their money. He later told the victims that he had arranged to send their money to the fund by wire transfer but that the wire had not yet gone through. He subsequently sent the victims a document purportedly from his bank showing a balance of more than $800,000 in his account when, in fact, that account was overdrawn. The next day, TILSON sent the victims a purported bank document falsely indicating that he had wired the first victim's money back to him and another purported bank document falsely indicating that his account had a balance of more than $400,000 when the account was overdrawn. TILSON admitted to the victims that he had taken their money a few days later to make other payments.
Founder and Executive of Prior2IPO Indicted in Investment Fraud / Raymond Pirrello, Jr., Misrepresented to Investors “No Fee” Investment Opportunities That Actually Carried Significant Upfront Fees (DOJ Release)
https://www.justice.gov/usao-edny/pr/founder-and-executive-prior2ipo-indicted-investment-fraud
In the United States District Court for the Eastern District of New York, an Indictment https://www.justice.gov/d9/2023-12/cr-23-499_indictment.pdf was filed charging Raymond John Pirrello, Jr., a/k/a “Ray John,” with securities fraud conspiracy, wire fraud conspiracy and securities fraud involving offerings by Late Stage Management, LLC through several sales offices, including Prior2IPO which he controlled. As alleged in part in the DOJ Release:
[L]ate Stage was a New Jersey based manager of investment funds that bought and sold stock issued by privately held companies that anticipated an IPO. Late Stage worked with several sales offices throughout New Jersey, New York and Florida in order to promote the investments. The salespeople used pitches devised by Pirrello and his co-conspirators which consistently touted that the investments carried no upfront fee, and claimed that the only time Late Stage profited was on exit, when the company made its IPO or sold to a larger company, in which case it would be entitled to a 20% share of the investor’s profits. In reality, Late Stage charged substantial fees in the form of markups of stock ranging from 10 to 50% of the stock’s actual per share price. In total, between approximately March 2019 and July 2022, sales offices working on behalf of Late Stage raised approximately $528 million from investors and diverted approximately $88.6 million in undisclosed upfront markups to Pirrello and his co-conspirators.
Also READ: SEC Charges Five Unregistered Brokers, Four Companies in Widespread Pre-IPO Fraud Scheme / Scheme resulted in more than $525 million in unregistered offerings, netting defendants more than $88 million in illicit profits from undisclosed fees (SEC Release)
Arizona Man Charged with Defrauding Local Physician Out of $207,000 (DOJ Release)
https://www.justice.gov/usao-az/pr/arizona-man-charged-defrauding-local-physician-out-207000
In the United States District Court for the District of Arizona, an Indictment was filed against Jeremie Sowerby charging him with wire fraud and transactional money laundering. As alleged in part in the DOJ Release:
[S]owerby scammed a victim-investor, an Arizona physician, out of $207,000 under the guise of a purported risk-free investment opportunity called “Justice Capital.” Sowerby convinced the victim to invest in what he claimed to be an exclusive hedge fund investment opportunity that supposedly used a “bot” algorithm to invest in a product tied to the stock market. Sowerby claimed that the investment and its guaranteed rates of return could be withdrawn in cash or Bitcoin at any time. Instead, however, Sowerby stole the money and used it for himself, including for an $83,000 cashier’s check made out to an entity he owns and controls.
Sowerby was previously charged in a separate case, along with co-defendant Luis Ortega, in a 55-count indictment alleging that Sowerby and Ortega scammed hundreds of victims out of millions of dollars in a cryptocurrency investment scheme under the guise of three entities: Now Mining, VIP Mining, and Millennium Technologies. That case remains pending.
Former FBI Agent Trainee Pleads Guilty To Insider Trading Scheme (DOJ Release)
https://www.justice.gov/usao-sdny/pr/former-fbi-agent-trainee-pleads-guilty-insider-trading-scheme
In the United States District Court for the Southern District of New York, Seth Markin pled guilty to securities fraud involving trading in the stock of Pandion Therapeutics. As alleged in part in the DOJ Release:
In early 2021, SETH MARKIN and BRANDON WONG together made more than $1.4 million in illegal profits by trading in stock based on inside information that MARKIN stole from his then-girlfriend, who was at the time an attorney at a major law firm in Washington D.C. (the “Law Firm Associate”). At the time, MARKIN had been accepted into the Federal Bureau of Investigation (“FBI”) as a new agent trainee, and WONG was a systems analyst at an education company. In February 2021, MARKIN secretly looked through the Law Firm Associate’s confidential work documents, without her permission, and learned that, in a matter of weeks, Merck, a publicly traded pharmaceutical company, was going to acquire Pandion, a publicly traded biotechnology company, for approximately three times the value of Pandion’s share price. MARKIN immediately purchased Pandion stock on the basis of this material non-public information and also told several family members and friends to purchase Pandion’s stock, causing WONG, another friend, and several family members to do so, including Family Member-1, Family Member-2, Family Member-3, Family Member-4, and Friend-1. In text messages, MARKIN assured WONG that he was “not uncertain” that when the “news drop[ped]” about Pandion, the price would “EXPLODE” and they would earn “triple gains.”
WONG purchased hundreds of thousands of dollars’ worth of Pandion shares based on the material non-public information he received from MARKIN. In addition to his purchases of Pandion stock, WONG told at least seven other people to purchase Pandion shares, causing some of the people he tipped to purchase tens or hundreds of thousands of dollars’ worth of Pandion stock, including Family Member-5, Friend-2, Friend-3, Friend-4, Friend-5, Friend-6, and Friend-7.
In total, MARKIN and WONG together caused at least 20 people to trade in Pandion stock based on the material non-public information that MARKIN misappropriated from his girlfriend, resulting in millions of dollars of illegally obtained trading profits. To conceal their illegal insider trading scheme, MARKIN and WONG used an encrypted messaging application and deleted many of their text messages with each other. They also agreed on a cover story that they could provide to law enforcement, namely, that if they were asked how they anticipated Pandion’s stock price increase, they could say they “read it on Stocktwit,” in reference to a social media platform for sharing stock ideas, and falsely say that the news was “publicly being announced there.”
After Merck’s acquisition of Pandion was announced publicly, and the Pandion stockholdings of MARKIN and WONG, and those whom they tipped, significantly increased in value, the defendants sold their shares of Pandion for significant profits. With their illegal profits, the defendants and their tippees purchased luxury items and bought gifts for each other. For example, WONG purchased for MARKIN a Rolex watch valued at approximately $40,000, a trip to Hawaii, and a meal at a three-Michelin-starred restaurant in New York that cost more than $1,000. WONG also purchased a home in Florida.
Thereafter, MARKIN lied in order to hide his illegal insider trading. In or about June 2021, after MARKIN and the Law Firm Associate had ended their relationship, and as MARKIN was preparing to begin training as a new agent at the FBI Academy in Quantico, Virginia, the Law Firm Associate called MARKIN to ask why MARKIN’s name had come up in an inquiry by the Financial Industry Regulatory Authority into trading in Pandion stock. In response, MARKIN lied to the Law Firm Associate and falsely claimed that he did not trade in Pandion stock.
MARKIN subsequently took steps to further conceal his criminal activity. On November 18, 2021, Markin lied to FBI agents when he was interviewed about his Pandion trading. That day, Special Agents from the FBI interviewed MARKIN in connection with an investigation they told him was being conducted by law enforcement in the Southern District of New York relating to insider trading in Pandion stock. During the interview, MARKIN adhered to the fake cover story he and WONG had concocted and falsely told the agents (i) that he learned about Pandion on StockTwits, (ii) that he purchased the stock because of a recent earnings report and a new board member addition, and (iii) that he did not know that his former girlfriend worked on the Pandion transaction.
* * *
MARKIN, 32, of Washington Crossing, Pennsylvania, pled guilty to one count of securities fraud, which carries a maximum term of 20 years in prison.
WONG, 40, of New York, New York, pled guilty on April 10, 2023, to one count of securities fraud, which carries a maximum term of 20 years in prison.
BRIAN WONG, 45, of Secaucus, New Jersey, pled guilty on November 10, 2022, to being an accessory after the fact to conspiracy to commit securities fraud and tender offer fraud, which carries a maximum term of two and a half years in prison, and was sentenced on April 12, 2023, to three years’ probation with three months’ home confinement and forfeiture in the amount of $403,375.75.
JONATHAN BECKER, 34, of Weehawken, New Jersey, pled guilty on September 20, 2023, to one count of securities fraud, which carries a maximum term of 20 years in prison.
Former Principals Of Private “Pre-IPO” Funds Charged In Connection With $386 Million Fraud Scheme / Michael Castillero, Francine Lanaia, and Brian Martinsen Are Alleged to Have Defrauded Investors in Straightpath Funds by Selling Shares in Non-Public Companies at Arbitrarily Inflated Prices and Pocketing Hidden Markups (DOJ Release)
https://www.justice.gov/usao-sdny/pr/former-principals-private-pre-ipo-funds-charged-connection-386-million-fraud-scheme
In the United States District Court for the Southern District of New York, an Indictment https://www.justice.gov/d9/2023-11/u.s._v._castillero_et_al_indictment.pdf was filed charging MICHAEL CASTILLERO, a/k/a Michael Alejandro, FRANCINE LANAIA, and BRIAN MARTINSEN with conspiracy, securities fraud, wire fraud, and investment adviser fraud in connection with their management of StraightPath Venture Partners LLC (“SPVP”), StraightPath Management LLC, and nine related StraightPath Funds. Also, CASTILLERO and MARTINSEN were charged with conspiracy to obstruct justice and obstruction of justice in connection with their deletion of records that had been subpoenaed by the Securities and Exchange Commission (“SEC”). As alleged in part in the DOJ Release:
From at least in or about 2017 through at least in or about April 2022, CASTILLERO, LANAIA, and MARTINSEN engaged in a scheme to defraud investors in a group of nine related private funds known generally as the “StraightPath Funds.” In particular, the defendants, and others working at their direction, used “boiler room”-style call centers to market the StraightPath Funds, including to individual, non-professional investors, as presenting an opportunity to invest in privately held companies expected to go public in the near future (“pre-IPO companies”). The defendants purported to offer investors the chance to acquire shares in pre-IPO companies at favorable prices in advance of an anticipated public offering, at which time, they claimed, the shares would be worth significantly more.
Although the defendants and their agents represented to existing and prospective investors in the StraightPath Funds that the defendants would earn no upfront fees in connection with the StraightPath Funds’ acquisition of pre-IPO shares, in reality, and contrary to their fiduciary duties, the defendants acquired the shares and then sold them to investors at arbitrarily inflated and excessive prices without disclosing to investors the nature or extent of the markup. The defendants also misled investors regarding the nature of their investments and hid the involvement of CASTILLERO and LANAIA who had been previously barred from the securities industry by the Financial Industry Regulatory Authority (“FINRA”). Moreover, in order to evade detection of their scheme, CASTILLERO and BRIAN MARTINSEN destroyed records and otherwise obstructed the efforts of the SEC to uncover the defendants’ fraud on investors.
In order to generate interest in the StraightPath Funds among retail investors, CASTILLERO, LANAIA, and MARTINSEN used finders, or “referral agents,” to pitch prospective investors and thereafter to serve as the investors’ primary point of contact. In turn, these agents used “boiler room”-style call centers to cold-call potential investors, many of whom were not sophisticated, and give aggressive sales pitches using notes and pitch scripts approved by the defendants. Contrary to the defendants’ claim that they and their agents did not make money unless and until investors received a profit on their investments, SPVP paid referral agents a commission, typically a 10 to 15 percent front-end fee based on the amount of the investment, plus a portion of the carried interest on the back end.
In addition to misleading prospective investors about the compensation paid to referral agents, CASTILLERO, LANAIA, and MARTINSEN defrauded investors in the StraightPath Funds, for which they acted as fiduciaries, by (i) charging investors excessive and undisclosed markups on share prices of pre-IPO companies, which benefited the defendants and their associates at the expense of investors and the StraightPath Funds; (ii) routinely overstating to investors the number of pre-IPO shares that backed the interests in StraightPath Funds they sold; (iii) falsely representing that investors were investing in a specific “Series” within a specific StraightPath Fund and that their contributions correlated to specific shares of specific pre-IPO companies, when, in actuality, investor funds were commingled across Series and Funds and used for purposes not disclosed to investors, including to pay out other investors and to compensate the defendants and their associates; (iv) falsely representing that a particular individual (“Fund Manager-1”) acted as manager of each of the StraightPath Funds and the SP Adviser when, in actuality, CASTILLERO, LANAIA, and MARTINSEN performed the functions ascribed to Fund Manager-1 in StraightPath’s offering documents including, among other things, using an email address in the name of Fund Manager-1 to correspond with investors; and (v) otherwise actively taking steps to prevent investors from learning about LANAIA’s and CASTILLERO’s leadership roles in light of the fact that both had been suspended and later permanently barred from involvement in the securities industry by FINRA.
Throughout the StraightPath Funds’ operation, CASTILLERO, LANAIA, and MARTINSEN actively took steps to conceal the true nature of SPVP’s operations not only from investors but also from regulatory bodies, including FINRA and the SEC. For example, MARTINSEN, CASTILLERO, and LANAIA discussed making Fund Manager-1 the scapegoat with the SEC, in the event the SEC identified any problems with StraightPath’s operations. MARTINSEN then added, “Fran [LANAIA] is going to wamboosle the sec lady tomorrow. They will talk weather for 45 min and the lady will forget what she’s looking for.”
In early May 2021, MARTINSEN and CASTILLERO agreed to and did delete certain email records that had been called for by an SEC subpoena and then falsely represented to SEC staff that the emails had never existed.
The StraightPath entities and StraightPath Funds are no longer operational and are under the control of a court-appointed Receiver tasked with taking possession of StraightPath’s assets and recommending a plan to return value to investors.
[B]ajic and his co-conspirators owned and/or controlled numerous foreign corporations that they used to conceal the common ownership of shares of various microcap companies’ that traded on the stock market. It is alleged that Bajic and his co-conspirators used these nominee entities to hold shares in blocks of just under five percent of the underlying companies’ total outstanding shares, in order to conceal from transfer agents and the investing public that the shares were under common control and subject to sale restrictions under the federal securities laws. Bajic and his co-conspirators then allegedly sold the shares at the control persons’ direction during promotional campaigns intended to create investor demand for the shares (conduct known as a “pump-and-dump”). Bajic and his co-conspirators also allegedly distributed the illicit proceeds for the control persons’ benefit while keeping commissions for themselves. In total, Bajic and his co-conspirators are alleged to have facilitated the sale of the securities of dozens of microcap companies for trading proceeds in the tens of millions of dollars, including over $6 million generated from the sale of shares of the company Blake Insomnia Therapeutics, Inc. (ticker symbol BKIT).
Through his employment at TIAA-CREF, BILLIMEK had advance access to certain of TIAA-CREF’s anticipated trades. Due to the size of certain of these TIAA-CREF trade orders, they often caused market movement in the securities they traded. From at least 2016 through his arrest in December 2022, BILLIMEK misused his insider access and provided inside information about these trades to his co-conspirator (“CC-1”) who then bought or sold the same securities in advance of the TIAA-CREF trading. CC-1 then provided BILLIMEK with a portion of the profits on these trades.
BILLIMEK and CC-1 engaged in these front-running trades on over a thousand occasions between in or about 2016 and December 2022. In an effort to hide their scheme, BILLIMEK used prepaid, unregistered “burner” phones to communicate with CC-1 throughout the trading day. BILLIMEK and CC-1 also lied to various financial institutions about the source of funds they received during the scheme, claiming that they were, among other things, gifts. In total, BILLIMEK and CC-1 generated tens of millions of dollars in profits.
Recidivist Fraudster Sentenced To 212 Months In Prison In Connection With $40 Million Ponzi Scheme And Other Frauds (DOJ Release)
https://www.justice.gov/usao-sdny/pr/recidivist-fraudster-sentenced-212-months-prison-connection-40-million-ponzi-scheme
In the United States District Court for the Southern District of New York, Franklin Ray, 52, pled guilty to four counts of wire fraud and one count of aggravated identity theft.; and he was sentenced to 212 months in prison plus five years of supervised release and ordered to forfeit $42,128,912.00 and several assets, including a 1968 Chevy Camaro. As alleged in part in the DOJ Release:
Beginning in at least June 2021, FRANKLIN RAY began to offer investors an opportunity to invest in his trucking and logistics company, CSA Business Solutions LLC (the “Truck Investment Scheme”). Specifically, RAY and the investors entered into contracts pursuant to which CSA Business Solutions LLC would procure and operate a truck in its trucking business for each $20,000 contributed by the investor. RAY told investors that the trucks would perform delivery services for a multinational e-commerce company and/or a multinational shipping company and that the investors would be entitled to 77% of the net income of the trucks. In reality, CSA Business Solutions LLC operated few trucks and had minimal revenues from trucking activities. Instead, investors in the Truck Investment Scheme received payments from new investments into the scheme or from other sources. After the investors purchased the rights to trucks from CSA Business Solutions LLC, RAY sent them falsified spreadsheets at regular intervals, purporting to show the performance of their trucks during the relevant period. RAY ultimately persuaded approximately 275 investors to invest at least $40 million and fraudulently claimed to have purchased over 2,000 trucks with the investments.
RAY also carried out fraudulent schemes to obtain over $1.9 million in government-guaranteed loans designed to provide relief to small businesses during the COVID-19 pandemic on behalf of CSA Business Solutions LLC and another Michigan-based trucking company (the “SBA Loan Fraud Schemes”). In connection with the SBA Loan Fraud Schemes, RAY submitted false information and forged documents to the Small Business Administration and commercial lenders. RAY claimed that these businesses engaged in significant trucking business, but they had minimal revenues and trucking activity. RAY also committed aggravated identity theft with respect to one of the SBA Loan Fraud Schemes.
In addition, RAY fraudulently induced a New York City-based real estate company (the “Company”) to pay $175,000 in startup costs for a joint venture (the “Joint Venture”) between the Company and CSA Business Solutions LLC. In order to persuade the Company to enter into the Joint Venture and pay the $175,000, RAY lied about his personal business experience and the trucking business conducted by CSA Business Solutions LLC. Rather than pay for startup costs, RAY spent the funds on personal expenses, including private airplane trips. The Joint Venture was never formed.
RAY was arrested in early March 2022, and a CSA Business Solutions LLC bank account was seized at that time. After his arrest, up until his Indictment in April 2022, RAY continued to operate the Truck Investment Scheme. RAY hid the fact of his arrest and the seizure of the bank account and lied to investors about why he did not make expected payments after his arrest. During the period after his arrest, RAY opened new bank accounts on behalf of CSA Business Solutions LLC and continued to solicit and accept investor funds for trucks that did not exist. In the post-arrest period alone, RAY defrauded investors into paying at least $1.9 million into his scheme.
RAY previously pled guilty to bank fraud and wire fraud in the Eastern District of Michigan. He received a two-year sentence in connection with those crimes and was released from federal custody in 2010.
United Kingdom National Pleads Guilty to Hacking, Securities Fraud, and other Cybercrimes / Scheme Netted More than $6 Million (DOJ Release)
https://www.justice.gov/usao-edny/pr/united-kingdom-national-pleads-guilty-hacking-securities-fraud-and-other-cybercrimes
In the United States District Court for the Eastern District of New York, Idris Dayo Mustapha, 33, pled guilty to charges of computer intrusion, securities fraud, wire fraud and access device fraud. As alleged in part in the DOJ Release:
[B]etween 2011 and 2018, Mustapha and his co-conspirators hacked into the computer servers of U.S. financial institutions, reviewed confidential user data, and placed malicious files on the servers. Using the stolen data and stolen passwords that they acquired, they executed various schemes to defraud U.S. victims. First, they accessed victims’ email accounts and, impersonating the victims, caused wire transfers of the victims’ funds for their own benefit. Second, they used their access to the victims’ securities brokerage accounts to steal securities outright by having them transferred out of the accounts. Third, Mustapha and his co-conspirators caused the victims’ brokerage accounts to execute unfavorable trades against accounts that Mustapha and his co-conspirators controlled, generating a profit for themselves at the victims’ expense. Losses attributable to the scheme were in excess of $6 million.
SEC
SEC Charges Five Unregistered Brokers, Four Companies in Widespread Pre-IPO Fraud Scheme / Scheme resulted in more than $525 million in unregistered offerings, netting defendants more than $88 million in illicit profits from undisclosed fees (SEC Release)
https://www.sec.gov/news/press-release/2023-245
In the United States District Court for the Eastern District of New York, the SEC filed a Complaint https://www.sec.gov/files/litigation/complaints/2023/comp-pr2023-245.pdf that charges Raymond J. Pirrello, Jr., Marcello Follano, Robert Cassino, Anthony DiTucci, Joseph Rivera, and their companies Prior 2 IPO Inc., Late Stage Asset Management, LLC, Pre IPO Marketing Inc., and JL Rivera Enterprises Ltd. with violations of the antifraud, securities and broker-dealer registration, and other provisions of the federal securities laws. As alleged in part in the SEC Release:
[D]efendants employed a nationwide network of unregistered sales agents to raise at least $528 million in unregistered offerings of pre-IPO securities from more than 4,000 investors around the world. The complaint alleges that the defendants falsely told investors that there were no upfront fees on the offerings and that the defendants would only make a profit after the pre-IPO companies went public; however, all investors were charged undisclosed upfront markups, some as high as 150 percent, from which the defendants and their network of unregistered sales agents pocketed more than $88 million.
. . .
The SEC alleges that the charged individuals went to great lengths to conceal the identity of one of the scheme’s ringleaders, Pirrello, from investors and potential employees to hide the fact that he was barred from associating with broker-dealers in an earlier administrative proceeding by the SEC, after a jury found him liable for insider trading in August 2019.
Also READ: Founder and Executive of Prior2IPO Indicted in Investment Fraud / Raymond Pirrello, Jr., Misrepresented to Investors “No Fee” Investment Opportunities That Actually Carried Significant Upfront Fees (DOJ Release)
“They Are Merely the Agents”Prepared Remarks before the American Bar Association by SEC Chair Gary Gensler
https://www.sec.gov/news/speech/gensler-prepared-remarks-american-bar-association-231207
Good morning. I am pleased to speak before the American Bar Association for the Federal Regulation of Securities Winter Meeting. As is customary, I’d like to note that my views are my own as Chair of the Securities and Exchange Commission, and I am not speaking on behalf of my fellow Commissioners or the SEC staff.
When President Franklin Roosevelt and Congress came together to craft the federal securities laws and the SEC to oversee them, they understood the critical role that corporate governance plays to protect investors and facilitate capital formation.
Rules around corporate governance help better align the interests of managers with those of shareholders. This helps to build trust, which lowers risk premiums for investors and lowers the cost of capital for issuers. Trust also promotes greater participation by investors in the markets. Put another way, good corporate governance is good for issuers and investors alike.
When Roosevelt and Congress were setting up the federal securities laws, debates around corporate governance were far from new. Those debates go back to the first joint-stock company founded in 1602, the Dutch East India Company.[1] In preparing for this speech, I found an article from 1825, where a critic in the New-York National Advocate wrote: “We complain of directors considering themselves the company, when they are merely the agents.”[2]
In the 1930s, corporate governance was fresh on Roosevelt and Congress’s minds. In a series of high-profile Congressional hearings, Ferdinand Pecora and others uncovered widespread abuses where executives at Insull, National City Bank, and other corporations enriched themselves while hurting shareholders of their own companies and damaging public trust in financial markets more generally.[3]
In the wake of the hearings, Roosevelt and Congress enacted laws in which the federal government, through the SEC, had a role to play to address these issues. This role would stand alongside state law.
Further, though Congress conceived the SEC primarily as a disclosure-based agency, there were places where the securities laws went beyond disclosure alone, particularly in a number of areas related to corporate governance.
In addition to disclosure by issuers regarding corporate governance itself, I think of three other areas where Congress included provisions related to corporate governance. First, Congress included provisions related to how corporate governance can help enhance the integrity of all other disclosures. Second, Congress included provisions related to shareholder voting and acquisition of control of issuers. Third, Congress included provisions regarding executive compensation and ill-gotten compensation, including insider trading.
As securities laws practitioners, you recognize where these principles appeared in the first federal securities laws.
In Section 11 of the ’33 Act, Congress imposed on directors and officers liability for inaccurate registration statements. In Section 14 of the ’34 Act, Congress required disclosures and guardrails around solicitations of authority to vote on shareholders’ behalf, so-called proxies. Section 16 of the ’34 Act included a prophylactic rule about insider trading relating to short-swing profits.
Subsequently, in the decades after the New Deal, Congress repeatedly revisited, reaffirmed, and expanded the SEC’s role with respect to disclosure and guardrails related to corporate governance. Let me focus on three instances.
In the Williams Act of 1968, Congress added provisions to Section 14 relating to tender offers and disclosure requirements from beneficial owners attempting to gain control of a company.
In my first job on Wall Street, working in mergers and acquisitions, I observed time and again as board members, with a tender offer on the table, asked their lawyers for briefings not only on state law such as Delaware law, but also on the federal securities laws—including the Williams Act. I took comfort in knowing there were such federal laws on the books, seeing how they build trust in the markets and companies’ governance.
After Enron and Worldcom’s historic bankruptcies, as part of the Sarbanes-Oxley Act of 2002, Congress revisited corporate governance-related issues in the securities laws. Congress required companies to have audit committees and enacted provisions to promote audit integrity. Further, Congress added to insiders’ accountability for accurate disclosures[4] and enacted an important clawback provision.[5]
Following the 2008 financial crisis, as part of the Dodd-Frank Act of 2010, Congress again returned to corporate governance-related issues in the securities laws. In Dodd-Frank, Congress mandated that the SEC enact several additional rules on corporate governance regarding clawbacks and executive compensation, for example.
Rulemaking Initiatives
In the last two years, the SEC has taken on a number of rulemaking initiatives related to corporate governance.
Through these rulemakings, we are working to update our ruleset to keep pace with ever-evolving technology and business models, as well as to implement Congress’s mandates.
These projects draw broadly upon those principles going back to the 1930s.
Executive Compensation
First, we took on a number of unfulfilled Dodd-Frank mandates related to executive compensation.
Last year, we fulfilled a Dodd-Frank mandate by adopting a set of clawback rules.[6] In essence, if a company makes a material error in preparing a financial statement, an executive may receive compensation for reaching a milestone that was never actually hit. It’s common sense to require issuers to “claw back” that erroneously awarded pay. That money belongs to the company and its shareholders. Such rules ensure that executives don’t keep compensation they should not have received. The rules also strengthen the incentives for executives to make sure a company’s financial disclosures are accurate, promoting the integrity of financial statements.
Among other things, the rules require exchanges to propose and implement listing standards requiring all issuers on their exchange to develop and implement a clawback policy that fulfills our final rules. In October of this year, those listing standards became effective, and by December 1—last week—all issuers that list securities on those exchanges were required to develop and implement their clawback policies.[7]
We also adopted rules related to disclosure of executive pay versus performance.[8] Fulfilling Congress’s mandate, our final rules require companies to make clear disclosure to investors on the relationship between a company’s executive compensation actually paid and the company’s financial performance. It helps align incentives when a company’s investors understand which factors may influence the compensation of its executives.
In Section 956 of the Dodd-Frank Act, Congress mandated that the SEC—working with five other financial regulators—prescribe regulations with respect to incentive-based compensation practices at financial institutions. We stand ready to work with our fellow regulators to fulfill this mandate and through re-proposing rules in this area.[9]
Insider Trading
Second, few things undermine trust in the markets more than insiders abusing their positions for personal advantage, such as by trading using material nonpublic information.
Company executives usually receive stock-based compensation, which can help align incentives between investors and management. Those executives, however, have nonpublic information about the companies they lead, so it’s important that investors have confidence that these company insiders cannot use material nonpublic information to get an unfair advantage when trading their companies’ stock.
In 2000, the SEC adopted Exchange Act Rule 10b5-1. The rule provided affirmative defenses for corporate insiders and companies to buy and sell stock as long as they adopted their trading plans in good faith, before becoming aware of material nonpublic information. In the subsequent two decades, however, it became clear that gaps had emerged in the rule. Insiders could benefit from the rule’s liability protections while trading securities opportunistically on the basis of material nonpublic information.
Thus, last year, we adopted amendments to fill these gaps, such as by imposing a cooling-off period between when insiders can adopt plans and trade under those plans, limiting the number of plans insiders can have, and requiring insiders to certify that they’re not in possession of material non-public information.[10] The rule went into effect in February 2023.[11]
These steps help align incentives, avoid improper gains, and build trust amongst investors and issuers.
Proxy Voting
The third category of our projects relates to proxy voting. These projects build on those ’34 Act authorities I mentioned, whereby Congress established the SEC’s role with respect to solicitation of shareholder proxies—an important aspect of corporate governance. It is through the proxy voting process and director elections that shareholders, as the owners of the corporation, can hold the board and management accountable for the corporation’s performance.
In 2021, the Commission adopted rules relating to universal proxy.[12] The ability to elect directors is among the most important rights of shareholders. It’s thus important that shareholders—as a company’s owners—get to pick and vote for their preferred mix of candidates when voting by proxy, regardless of who nominated them.
The final rules put investors voting in person and by proxy on equal footing, which enhances shareholder voting.
Additionally, last year, the Commission adopted amendments to enhance the transparency of fund and institutional investment managers’ proxy voting records.[13] Our final rules make sure that investors receive consistent and more detailed information about proxy votes. Importantly, the rules also fulfill a Dodd-Frank mandate including with regard to how investment managers vote on executive compensation—or so-called “say-on-pay” matters.
The Commission also adopted amendments to the rules governing proxy voting advice. The rules are designed to address issues concerning the timeliness and independence of proxy voting advice, which will help to protect investors and facilitate shareholder voting.[14]
Also in 2022, the Commission proposed amendments to Rule 14a-8.[15] Our proposal, if adopted, would bring more clarity and consistency to how companies evaluate shareholder proposals for inclusion in their proxy statements.
Beneficial Ownership
Lastly, in October, we adopted rules to shorten the deadlines by which beneficial owners must inform the public of their position.[16] Though these rules don’t govern corporate directors and officers, they nevertheless relate to corporate governance principles regarding shareholder voting and corporate control.
The Williams Act, as amended in 1970, provided that beneficial owners with control positions of more than 5 percent had to report those positions within 10 days.
In Dodd-Frank, Congress authorized the SEC to enact rules to modify those 10-day deadlines. Recently, we adopted amendments to shorten these reporting deadlines to five business days. This adoption updates these reporting requirements for modern markets, ensures investors receive material information in a more timely way, and reduces information asymmetries.
Conclusion
Here at the SEC, we have gotten a lot done to update and enhance corporate governance for the 2020s.
Our projects align with our authorities in corporate governance going back nine decades.
They follow Congress’s vision that a federal regulator, the SEC, play a role alongside state law in addressing corporate governance-related issues—to align incentives and build trust in the markets.
That benefits investors and issuers alike.
[1] See Giuseppe Dari-Mattiacci et al., “The Emergence of the Corporate Form,” 33 Journal of Law, Economics, and Organization (March 24, 2017), 193, available at https://academic.oup.com/jleo/article/33/2/193/3089484. Page 193 discusses Dutch invention of a joint-stock corporation.
[2] See Eric Hilt, Journal of Economic History, “When Did Ownership Separate from Control? Corporate Governance in the Early Nineteenth Century” (September 2008), 645, Footnote 1, available at https://www.jstor.org/stable/40056434?read-now=1&seq=1#page_scan_tab_contents.
[3] See Joel Seligman, “The Transformation of Wall Street: A History of the Securities and Exchange Commission and Modern Corporate Finance, Third Edition” (June 2003), Chapter 1.
[4] See Section 302 of the Sarbanes-Oxley Act.
[5] As summarized in an SEC press release regarding a 2012 enforcement action relating to this clawback provision: “Section 304 of the Sarbanes-Oxley Act provides for reimbursement by some senior corporate executives of certain compensation and stock sale profits received while their companies were in material non-compliance with financial reporting requirements due to misconduct. The ‘clawback’ provision can include an individual who has not been personally charged with the underlying misconduct or alleged to have otherwise violated the federal securities laws.” See Securities and Exchange Commission, “SEC Sues Two Executives in Texas to Recover Bonuses and Stock Profits Received During Accounting Fraud” (April 2, 2012), available at https://www.sec.gov/news/press-release/2012-2012-51htm.
[6] See Securities and Exchange Commission, “SEC Adopts Compensation Recovery Listing Standards and Disclosure Rules” (Oct. 26, 2022), available at https://www.sec.gov/news/press-release/2022-192.
[7] Ibid. As published in the SEC’s press release alongside the October 26, 2022, adoption: “The final rules will become effective 60 days following publication of the adopting release in the Federal Register. Exchanges will be required to file proposed listing standards no later than 90 days following publication of the release in the Federal Register, and the listing standards must be effective no later than one year following such publication. Issuers subject to such listing standards will be required to adopt a recovery policy no later than 60 days following the date on which the applicable listing standards become effective.”
[8] See Securities and Exchange Commission, “SEC Adopts Pay Versus Performance Disclosure Rules” (Aug. 25, 2022), available at https://www.sec.gov/news/press-release/2022-149.
[9] See Securities and Exchange Commission, Fall 2023 Agency Rule List, “Incentive-Based Compensation Arrangements” (Dec. 6, 2023), available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202310&RIN=3235-AL06. The other regulators include the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Federal Housing Finance Agency, and the National Credit Union Administration.
[10] See Securities and Exchange Commission, “SEC Adopts Amendments to Modernize Rule 10b5-1 Insider Trading Plans and Related Disclosures” (Dec. 14, 2022), available at https://www.sec.gov/news/press-release/2022-222.
[11] Ibid. As published in the SEC’s press release alongside the December 14, 2022, adoption: “The final rules will become effective 60 days following publication of the adopting release in the Federal Register. Section 16 reporting persons will be required to comply with the amendments to Forms 4 and 5 for beneficial ownership reports filed on or after April 1, 2023. Issuers will be required to comply with the new disclosure requirements in Exchange Act periodic reports on Forms 10-Q, 10-K and 20-F and in any proxy or information statements in the first filing that covers the first full fiscal period that begins on or after April 1, 2023. The final amendments defer by six months the date of compliance with the additional disclosure requirements for smaller reporting companies.”
[12] See Securities and Exchange Commission, “SEC Adopts New Rules for Universal Proxy Cards in Contested Director Elections” (Nov. 17, 2021), available at https://www.sec.gov/news/press-release/2021-235.
[13] See Securities and Exchange Commission, “SEC Adopts Rules to Enhance Proxy Voting Disclosure by Registered Investment Funds and Require Disclosure of ‘Say-on-Pay’ Votes for Institutional Investment Managers” (Nov. 2, 2022), available at https://www.sec.gov/news/press-release/2022-198.
[14] See Securities and Exchange Commission, “SEC Adopts Amendments to Proxy Rules Governing Proxy Voting Advice” (July 13, 2022), available at https://www.sec.gov/news/press-release/2022-120.
[15] See Securities and Exchange Commission, “SEC Proposes Amendments to Shareholder Proposal Rule” (July 13, 2022), available at https://www.sec.gov/news/press-release/2022-121.
[16] See Securities and Exchange Commission, “SEC Adopts Amendments to Rules Governing Beneficial Ownership Reporting” (Oct. 10, 2023), available at https://www.sec.gov/news/press-release/2023-219.
SEC Obtains Judgments Against Former Hemp Company Executives for Fraudulent Offerings (SEC Release)
https://www.sec.gov/litigation/litreleases/lr-25906
The United States District Court for the Southern District of New York entered Consent Judgments against Frank Barone and Kirill Chumenko, (former Senior Vice Presidents of Sales & Marketing at CanaFarma Hemp Products Corp.). Previously, CanaFarma co-founders Vitaly Fargesen and Igor Palatnik were charged by the SEC in connection with with the same alleged offering fraud. As alleged in part in the SEC Release:
[I]n 2019 and 2020, Barone and Chumenko, along with CanaFarma, Fargesen, and Palatnik, raised millions of dollars from investors. While raising these funds, Fargesen and Palatnik made misrepresentations to investors, including claims that CanaFarma was a fully integrated company that was processing hemp from its own farm when in fact it had not processed any of this hemp and its products used hemp supplied by third parties. The amended complaint alleges that Barone and Chumenko, at the direction of Fargesen, made unsupported changes to CanaFarma’s financial model in order to disguise an expected series of payments to Fargesen and Palatnik. Additionally, the amended complaint alleges that, Fargesen and Palatnik—in some instances with the assistance of Barone and Chumenko—misappropriated at least $4 million and used the funds either for their personal use or for purposes unrelated to CanaFarma.
In addition to the previously announced charges against CanaFarma, Fargesen, and Palatnik, the amended complaint, filed in the United States District Court for the Southern District of New York, charges Barone and Chumenko with violations of Sections 17(a)(1) and (3) of the Securities Act of 1933 (“Securities Act”) and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rules 10b-5(a) and (c) thereunder.
The judgments against Barone and Chumenko permanently enjoin them from violating Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder. The judgments also bar each of Barone and Chumenko from serving as an officer or director of a public company and from participating in penny stock offerings, and order each to pay disgorgement, prejudgment interest, and civil penalties. The length of the bars and the amounts of the monetary remedies will be determined by the Court upon motion of the SEC at a later date.
SEC Obtains Final Judgment Against CodeSmart Defendant for Role in Alleged Offering Fraud (SEC Release)
https://www.sec.gov/litigation/litreleases/lr-25905
The United States District Court for the Eastern District of New York entered a Final Judgment against Marc Wexler, enjoining him from violating certain provisions of the federal securities laws. As alleged in part in the SEC Release:
]S]tarting in 2013, Wexler was involved in a scheme to manipulate the price of the securities of CodeSmart Holdings, Inc. (“CodeSmart”). The SEC alleged that Wexler and others sought to flood the market with CodeSmart shares and engaged in a promotional campaign to artificially inflate the price of the stock. The SEC further alleged that Wexler personally dumped his CodeSmart shares on the market while working with two brokers who were at the same time purchasing CodeSmart stock in the accounts of their clients. In connection with this scheme, Wexler allegedly profited over $2 million.
The SEC’s complaint charged Wexler with violating Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933, Sections 9(a) and 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. On December 22, 2022, the Court entered a partial judgment against Wexler by consent in which he agreed to be permanently enjoined from violations of the charged provisions and agreed to a penny stock bar and officer-and-director bar. On December 4, 2023, the Court entered a final judgment against Wexler by consent in which he agreed to be permanently enjoined from violations of the charged provisions. He agreed to disgorge $2,218,599 in ill-gotten gains and prejudgment interest thereon, the payment of which was deemed satisfied by the restitution order in the parallel criminal proceeding, United States v. DiScala, et al., 14 Cr. 399 (E.D.N.Y.).
SEC Office of the Investor Advocate Publishes Its Policy Recommendations on Mandatory Arbitration and Registered Index-Linked Annuities Research
https://www.sec.gov/news/press-release/2023-244
Oh my! Just in time for Christmas!! Another useless but still lovely 56-page Report https://www.sec.gov/files/2023-oiad-annual-report.pdf from the SEC replete with some snow pictures and illustrations and clever graphs. Of course the cost of preparing this 2023 look-back isn't really worth anything for the investing public or industry but, y'know, that's never been much of a concern for any bureaucracy, right? What you get for this dud-of-a-bang-for-the-taxpayer's-buck are "highlights" about "research findings" and "metrics" and the ever-popular "topical discussions." An absolutely wonderful gift for any Wall Street professional or underwater investor's Christmas stocking. As set forth in the SEC Release:
The Office of the Investor Advocate of the Securities and Exchange Commission today published its Report on Activities for the Fiscal Year 2023 to Congress. The report highlights the work of the Office during the fiscal year.
Notable highlights from the report include:
-
- Empirical research findings about investors’ comprehension of registered index-linked annuities as well as policy recommendations;
- Research findings about investment advisory agreements use of mandatory arbitration clauses including suggested approaches on combating abusive use of those clauses;
- Metrics measuring the activities of the Office including the substantial uptick in investor engagement, investor submissions, and inquiries; and
- Topical discussions of private markets, cybersecurity, and equity market structure.
The Office of the Investor Advocate is an independent office within the SEC, created by Congress, to provide investors with a voice inside the Commission, to assist retail investors, to study investor behavior, and to support the Investor Advisory Committee of the Commission.
SEC Denies Whistleblower Award to Claimant Order Determining Whistleblower Award Claim ('34 Act Release No. 34-999079; Whistleblower Award Proc. File No. 2024-4)https://www.sec.gov/files/rules/other/2023/34-99079.pdfThe Claims Review Staff ("CRS") issued a Preliminary Determination recommending the denial of a Whistleblower Award to Claimant. The Commission ordered that CRS's recommendations be approved. The Order asserts in part that [Ed: footnotes omitted]:
[T]he CRS concluded that Claimant’s information did not either (1) cause the Commission to (a) commence an examination, open or reopen an investigation, or inquire into different conduct as part of a current Commission examination or investigation, and (b) thereafter bring an action based, in whole or in part, on conduct that was the subject of Claimant’s information, pursuant to Rule 21F-4(c)(1); or (2) significantly contribute to the success of a Commission judicial or administrative enforcement action under Rule 21F-4(c)(2) of the Exchange Act. The CRS determined that Claimant’s information was not the impetus for opening the investigation (“Investigation”) that resulted in the Covered Action and did not significantly contribute to the success of the Covered Action because Claimant provided information that was either already known to investigative staff, not materially relied upon in connection with the Investigation or Covered Action, or not relevant to the Investigation or Covered Action.
FINRA
FINRA Censures and Fines Windmill Group for Excessive Commissions
In the Matter of The Windmill Group, Inc., Respondent (FINRA AWC 2021069375901)
https://www.finra.org/sites/default/files/fda_documents/2021069375901
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, The Windmill Group, Inc. submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that The Windmill Group, Inc. has been a FINRA member since 1980 with about nine registered representatives. In accordance with the terms of the AWC, FINRA imposed upon The Windmill Group Inc. a Censure, $12,500 fine, and an undertaking to certify compliance with the issues cited. As alleged in the "Overview" of the AWC [Ed: footnote omitted]:
From June 2020 through April 2021. Windmill violated FINRA Rules 2121 and 2010 by charging two customers excessive commissions on 49 equity transactions. Additionally, from June 2020 to the present, Windmill failed to establish, maintain, and enforce a supervisory system. including written supervisory procedures (WSPs), reasonably designed to achieve compliance with Fl'.IRA rules related to discretionary trading and to fair commissions, in violation of FINRA Rules 3110 and 2010.
FINRA Censures and Fines SoFi Securities LLC, M1 Finance LLC, Sogo Trade, Inc., and Open to the Public Investing, Inc. for Fully Paid Securities Lending Supervision
In the Matter of SoFi Securities LLC, Respondent (FINRA AWC 2021072127101)
https://www.finra.org/sites/default/files/fda_documents/2021072127
101%20SoFi%20Securities%20LLC
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In the Matter of M1 Finance LLC, Respondent (FINRA AWC 2021072127401)
https://www.finra.org/sites/default/files/fda_documents/2021072127
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In the Matter of SogoTrade, Inc., Respondent (FINRA AWC 2021072127)
https://www.finra.org/sites/default/files/fda_documents/2021072127
801%20SogoTrade%20Inc.%20CRD%2017912%20AWC%20gg.pdf
In the Matter of Open to the Public Investing, Inc., Respondent (FINRA AWC 2021072127701)
https://www.finra.org/sites/default/files/fda_documents/2021072127701%20Open
%20to%20the%20Public%20Investing%2C%20Inc.%20CRD
%20127818%20AWC%20gg.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, SoFi Securities LLC, M1 Finance LLC, SogoTrade, Inc., and Open to the Public Investing, Inc., each submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted, As alleged in part in the AWCs, the firms distributed documents to retail investors containing misrepresentations about the compensation that those investors would receive for participating in fully paid securities lending in violation of FINRA Rule 2010 and 2210(d). FINRA imposed upon:
SoFi Securities Investing a Censure, $500,000 fine, and $198,282.39 in restitution plus interest
M1 Finance a Censure, $500,000 fine, and $736,917.86 in restitution plus interest.
SogoTrade a Censure, $100,000 fine, and $104,767.25 in restitution plus interest.
Open to the Public Investing a Censure, $500,000 fine, and $28,123.75 in restitution plus interest.
FINRA Fines and Suspends Rep for Discretionary Trading and Untimely U4 Disclosure
In the Matter of Matthew Mierzycki, Respondent (FINRA AWC 023078629101)
https://www.finra.org/sites/default/files/fda_documents/2023078629101
%20David%20Korsnack%20CRD%206442930%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Matthew Mierzycki submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Matthew Mierzycki was first registered in 2012 with Edward Jones. In accordance with the terms of the AWC, FINRA imposed upon Mierzycki a $10,000 and a four-month suspension from associating with any FINRA member in all capacities. As alleged in the "Overview" portion of the AWC:
Between December 31, 2020 and October 28, 2021, while associated with Edward Jones, Mierzycki exercised discretionary trading authority to effect over 500 trades in numerous customer accounts without first obtaining the prior written authorization of the customers. As a result, Mierzycki violated FINRA Rules 3260(b) and 2010.
While associated with Edward Jones, Mierzycki also failed to timely disclose three compromises with creditors on his Form U4. When Mierzycki became associated with Ameriprise, he failed to disclose one of the same compromises with a creditor. As a result, Mierzycki violated Article V, Section 2(c) of FINRA’s By-Laws and FINRA Rules 1122 and 2010.
FINRA Bars Rep for Unauthorized Series 7 Materials and Providing False Information
In the Matter of David Korsnack, Respondent (FINRA AWC 023078629101)
https://www.finra.org/sites/default/files/fda_documents/2023078629101
%20David%20Korsnack%20CRD%206442930%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, David Korsnack submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that David Korsnack was first registered in 2022 with Ameriprise Financial Services LLC. In accordance with the terms of the AWC, FINRA imposed upon Korsnack a Bar from associating with any FINRA member in all capacities. As alleged in part in the AWC:
On May 12, 2023, during the course of its investigation, FINRA asked Korsnack in a written request pursuant to FINRA Rule 8210 to detail his actions during his unscheduled break, including whether he accessed any notes, study materials or mobile device. In his May 23, 2023 written response, Korsnack stated that he accessed his locker to check for a text message from his wife, and did not access any materials. These statements were false in that Korsnack retrieved the phone from his car, not his locker, and accessed materials on his phone relevant to the Series 7 test he was taking.
Therefore, Korsnack violated FINRA Rules 8210 and 2010
FINRA Suspends Rep for Willful Untimely Disclosure of Felony Charges
In the Matter of Jacob David Frankel, Respondent (FINRA AWC 2022073749901)
https://www.finra.org/sites/default/files/fda_documents/2022073749901
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Jacob David Frankel submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Jacob David Frankel was first registered in 2016, and eventually was registered with Worden Capital Management LLC, SW Financial, and Paulson Investment Company. In accordance with the terms of the AWC, FINRA imposed upon Frankel a four-month suspension from associating with any FINRA member in all capacities. No fine was imposed based upon Frankel's financial status. The AWC asserts that:
Respondent understands that this settlement includes a finding that he willfully violated Rule 15l-1 of the Securities Exchange Act of 1934 and that under Article III, Section 4 of FINRA’s By-Laws, this makes him subject to statutory disqualification with respect to association with a member.
As alleged in part in the "Overview" of the AWC:
Between August 2020 and November 2021, Frankel willfully failed to timely disclose on his Uniform Application for Securities Industry Registration or Transfer (Form U4) multiple felony charges. As a result, Frankel violated Article V, Section 2(c) of FINRA’s By-Laws and FINRA Rules 1122 and 2010.
Additionally, between October 2021 and June 2022, in anticipation of joining another FINRA member firm, Frankel improperly removed and retained nonpublic personal customer information from the member firms with which he was associated. As a result of this conduct, Frankel violated FINRA Rule 2010.
FINRA Fines and Suspends Rep for Inaccurate Rep Code
In the Matter of Daniel H. Vatterott, Respondent (FINRA AWC 2021070570001)
https://www.finra.org/sites/default/files/fda_documents/2021070570001
%20Daniel%20H.%20Vatterott%20CRD%201263265%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Daniel H. Vatterott submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Daniel H. Vatterott was first registered in 1984, and by 2009 was registered with Morgan Stanley. In accordance with the terms of the AWC, FINRA imposed upon Vatterott a $5,000 fine and a six-month suspension from associating with any FINRA member in all capacities. As alleged in part in the "Overview" of the AWC:
From October 2017 through February 2021, Vatterott falsified the representative code for 558 trades in Morgan Stanley's order entry system, causing the firm's trade confirmations to show an inaccurate representative code. As a result, Vatterott violated FINRA Rule 2010, and he separately violated FINRA Rules 4511 and 2010 by causing Morgan Stanley to maintain inaccurate books and records.
FINRA Fines and Suspends Rep for Inaccurate Rep Code
In the Matter of Justin H. Parkhurst, Respondent (FINRA AWC 2020068810101)
https://www.finra.org/sites/default/files/fda_documents/2020068810101
%20Justin%20H.%20Parkhurst%20CRD%205202789%20AWC%20lp.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Justin H. Parkhurst submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Justin H. Parkhurst was first registered in 1996, and by 2021 was registered with Cambridge Investment Research, Inc.. In accordance with the terms of the AWC, FINRA imposed upon Pankhurst a $5,000 fine and a one-month suspension from associating with any FINRA member in all capacities. As alleged in part in the "Overview" of the AWC:
From May 2013 through April 2018, Parkhurst changed the representative code for 311 trades, causing the trade confirmations to show an inaccurate representative code. As a result, Parkhurst caused Morgan Stanley to maintain inaccurate books and records in violation of FINRA Rules 4511 and 2010.
FINRA Censures and Fines The Benchmark Company for Failing to Restrict Flow of Potentially Material Nonpublic Research Information
In the Matter of The Benchmark Company, LLC , Respondent (FINRA AWC 2019060649901)
https://www.finra.org/sites/default/files/fda_documents/2019060649901
%20The%20Benchmark%20Company%2C%20LLC%20CRD
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, The Benchmark Company, LLC, formerly known as Actinver Securities, Inc. submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Benchmark has been a FINRA member since 1989 with about 90 registered personnel at three branches (and employs about 30 personnel registered with FINRA as research analysts). In accordance with the terms of the AWC, FINRA imposed upon Benchmark a Censure and $450,000 fine. As alleged in part in the "Overview" of the AWC:
From February 2018 through February 2019, Benchmark failed to establish, maintain,and enforce policies and procedures reasonably designed to restrict the flow of potentially material nonpublic research information between the research department and sales and trading personnel or prevent the selective dissemination of potentially material nonpublic research information to certain customers. The firm's failures concern research notes, which were emails typically following a newsworthy event prepared by a research analyst, approved for external use by the firm's research department and distributed outside the research department in advance of published research reports. These research notes contained analysis drafted by a research analyst utilizing the firm's internal financial modeling, which informed Benchmark's views of covered companies, including ratings, price targets, and earnings estimates. The firm failed to reasonably address the risk that these types of research notes could constitute research reports or include material nonpublic information that the firm's sales and trading personnel might misuse, including the potential for sales and trading personnel to utilize non-public advance knowledge of the information for the benefit of the firm or any other person. The firm also failed to reasonably address the risk that firm personnel would selectively disseminate these types of research notes to parties external to Benchmark.
By virtue of the foregoing, Benchmark violated FINRA Rules 5280(b), 2241(g), 3110,and 2010.
FINRA Censures and Fines Actinver for Supervision of Pre-Arranged Trades
In the Matter of Altema Securities, Inc., formerly known as Actinver Securities, Inc., Respondent (FINRA AWC 2020068391502)
https://www.finra.org/sites/default/files/fda_documents/2020068391502
%20Alterna%20Securities%2C%20Inc.%2C%20fna%20Actinver
%20Securities%2C%20Inc.%20CRD%2041139%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Altema Securities, Inc., formerly known as Actinver Securities, Inc. submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Actinver has been a FINRA member since 1996 with about 45 registered representatives at four branches. In accordance with the terms of the AWC, FINRA imposed upon Actinver a Censure, $32,500 fine, and an undertaking to certify compliance with the cited issues. As alleged in part in the "Overview" of the AWC:
From at least April l, 2019, through September 30, 2020, Actinver's supervisory system,including written supervisory procedures (WSPs), was not reasonably designed to surveil for potentially manipulative pre-arranged trades. By virtue of the foregoing, the firm violated FINRA Rules 3110 and 2010.
FINRA Censures and Fines TIAA-CREF for Customer Complaints Reporting
In the Matter of TIAA-CREF Individual & Institutional Services, LLC, Respondent (FINRA AWC 2022073326001)
https://www.finra.org/sites/default/files/fda_documents/2022073326001
%20TIAA-CREF%20Individual%20%26%20Institutional%20Services
%2C%20LLC%20CRD%2020472%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, TIAA-CREF Individual & Institutional Services, LLC submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that TIAA-CREF has been a FINRA member since 1988 with about 3,500 registered representatives at 140 branches. In accordance with the terms of the AWC, FINRA imposed upon TIAA-CREF a Censure and $125,000 fine. As alleged in part in the "Overview" of the AWC:
From August 2018 to September 2022, TC Services failed to report promptly written customer complaints involving allegations of theft or misappropriation of funds or securities. During the same period, TC Services also failed to report settled matters where the firm was the subject of a claim for damages by a customer relating to the provision of financial services or a financial transaction and the settlement amount exceeded $25,000.
During the same period, TC Services also failed to establish and maintain a supervisory system, including written supervisory procedures, that were reasonably designed to achieve compliance with FINRA reporting rules.
As a result, TC Services violated FINRA Rules 4530(a)(1)(B) and (G), 3110 and 2010
FINRA Fines and Suspends Rep for Variable Annuities Recommendations
In the Matter of Malay Kumar, Respondent (FINRA AWC 2022077257801)
https://www.finra.org/sites/default/files/fda_documents/2022077257801
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Malay Kumar submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Malay Kumar was first registered in 1996, and by 2021 was registered with Cambridge Investment Research, Inc.. In accordance with the terms of the AWC, FINRA imposed upon Kumar a $10,000 fine, $50,103.43 restitution, and a 12-month suspension from associating with any FINRA member in all capacities. The AWC asserts that:
Respondent understands that this settlement includes a finding that he willfully violated Rule 15l-1 of the Securities Exchange Act of 1934 and that under Article III, Section 4 of FINRA’s By-Laws, this makes him subject to statutory disqualification with respect to association with a member.
As alleged in part in the "Overview" of the AWC:
Between June 2018 and October 2021, Kumar recommended that seven of his customers exchange variable annuities without reasonably considering the impact of the substantial surrender fees and the loss of benefits and liquidity caused by the exchanges. As a result, Kumar did not have a reasonable basis to believe that his recommendations were suitable or, after June 30, 2020, in his customers’ best interest. By this conduct, Kumar willfully violated the Care Obligation of Rule 15l-1 of the Securities Exchange Act of 1934 (Regulation BI or Reg BI), and violated FINRA Rules 2111, 2330, and 2010.
Between May 2018 and October 2021, Kumar provided inaccurate information about the source of funds on the transaction documents he submitted to the firm and the annuity issuers. Specifically, Kumar failed to identify and submit eighteen variable annuity purchases as exchanges even though each purchase was funded by the sale of another variable annuity. In doing so, Kumar caused his firm to create and maintain inaccurate books and records. As such, Kumar violated FINRA Rule 2010 by falsifying documents and making false statements and he separately violated FINRA Rules 4511 and 2010 by causing his firm to maintain inaccurate books and records.
FINRA Fines BofA Securities $24 Million for Treasuries Spoofing and Related Supervisory Failures / Firm Engaged in 717 Instances of Spoofing Activity (FINRA Release)
https://www.finra.org/media-center/newsreleases/2023/finra-fines-bofa-securities-24-million-for-treasuries-spoofing-and-related-supervisory-failures
WASHINGTON—FINRA announced today that it has fined BofA Securities, Inc. $24 million for engaging in more than 700 instances of spoofing through two former traders in U.S. Treasury secondary markets and related supervisory failures spanning more than six years.
“Spoofing undermines the transparency and integrity of the markets by distorting the true nature of supply and demand. Spoofing is especially detrimental in the U.S. Treasury securities market, given its status as a benchmark for countless financial instruments and transactions,” said Bill St. Louis, Executive Vice President and Head of Enforcement at FINRA. “This action sends a strong message that FINRA will aggressively pursue firms that engage in spoofing, including cross-product spoofing.”
Spoofing is a type of fraudulent trading that involves the use of non–bona fide orders (orders that the trader does not intend to have executed) to create a false appearance of market activity on one side of the market to induce other market participants to execute against bona fide orders entered on the opposite side of the market. Spoofing may deceive other market participants into trading at a time, price or quantity that they otherwise would not have.
From October 2014 through February 2021, BofA Securities, through a former supervisor and a former junior trader, engaged in 717 instances of spoofing in a U.S. Treasury security to induce opposite-side executions in the same Treasury security or a correlated Treasury futures contract.
From at least October 2014 through September 2022, BofA Securities failed to establish and maintain a supervisory system reasonably designed to detect spoofing in U.S. Treasury markets. BofA Securities did not have a supervisory system to detect spoofing in Treasuries until November 2015; until mid-2019, that system was deficient in that it was designed to detect spoofing by trading algorithms, not manual spoofing by its traders, like the 717 instances addressed in the settlement. In addition, until at least December 2020, BofA Securities’ surveillance did not capture orders its traders entered into certain systems provided by external venues. Lastly, BofA Securities did not supervise for potential cross-product spoofing in Treasuries through September 2022.
FINRA has discussed spoofing and related regulatory obligations in its Annual Risk Monitoring and Examination Priorities letters and its Examination and Risk Monitoring Program Reports, including its most recent 2023 Exam Report.
In settling this matter, BofA Securities consented to the entry of FINRA’s findings, without admitting or denying the charges.
READ the full-text BOA AWC Settlement https://www.finra.org/sites/default/files/2023-11/BofA-AWC-2019063152203-113023.pdf
Bill Singer's Comment: Perhaps nothing is more illustrative of the failure of the FINRA form of self-regulation than this statement in the AWC:
From at least October 2014 through September 2022, BofAS failed to establish and maintain a supervisory system reasonably designed to detect spoofing. BofAS did not have a supervisory system to detect spoofing in the U.S. Treasury markets until
November 2015. Thereafter, until mid-2019, BofAS’s surveillance was designed to detect spoofing by trading algorithms, not manual spoofing by its traders. In addition, until at least December 2020, BofAS’s surveillance did not capture orders its traders entered into
up to eight trading systems provided by external venues. BofAS also did not supervise for potential cross-product spoofing in the U.S. Treasury markets throughout the relevant period. Therefore, BofAS violated NASD Rule 3010 and FINRA Rules 3110 and 2010.
Okay, so, sure, go ahead and impose a $24 million fine on BOA, which will likely get paid out of the pockets of the company's public shareholders. And, yeah, while you're at it, issue your press releases touting the size of the fine and how it sends yet another message to the industry. But, while you're taking your dubious victory lap, howsabout you explain just what the hell FINRA was doing from 2014 through 2022 when BOA was not properly supervising its own spoofing?
2014. 2015. 2016. 2017. 2018. 2019. 2020. 2021. 2022. -- it sure as hell looks a lot worse when you set out each year that BOA was spoofing and failing to supervise its misconduct AND FINRA was regulating this member firm and the regulator itself was apparently clueless of both the spoofing and the unreasonable supervision. I accept that BOA engaged in misconduct and I have no sympathy whatsoever for the firm. On the other hand, either FINRA failed to oversee its member firm's protracted and serious misconduct; or, in the alternative, FINRA lacked (and still lacks) the competency to ferret out such attacks on the market's credibility. What we see here is a failure of in-house compliance coupled with a failure of industry self-regulation. It's long past due for this failed experiment in self-regulation to be shut down and replaced.
FINRA Fines and Suspends Rep for Impersonations
In the Matter of John Patterson Corey, Respondent (FINRA AWC 2022074939301)
https://www.finra.org/sites/default/files/fda_documents/2022074939301
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, John Patterson Corey submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that John Patterson Corey was first registered in 1982, and by 2018. In accordance with the terms of the AWC, FINRA imposed upon Pae a $5,000 fine and a 15-business-day suspension from associating with any FINRA member in all capacities. As alleged in part in the AWC:
On two occasions in June 2022, Corey called his former firm's customer service line for the purpose of assisting a customer with transferring his accounts from that firm to Thurston Springer Financial. During both calls, Corey impersonated the customer. On the first call, Corey could not provide answers to security questions, and the agent refused to provide Corey with any account information. On the second call, Corey was able to provide identifying information for the customer, and he successfully requested a copy of the customer's final account statement, which the firm sent to Corey's email address.
Although the customer had authorized Corey to assist with transferring his accounts, he did not authorize Corey to impersonate him. The customer did not suffer any loss and did not complain.
Therefore, Corey violated FINRA Rule 2010.
FINRA Fines and Suspends Rep for E-Commerce and Lead Generation OBAs
In the Matter of Ian James Prukner, Respondent (FINRA AWC 2022074939301)
https://www.finra.org/sites/default/files/fda_documents/2022074939301
%20Ian%20James%20Prukner%20CRD%205288581%20AWC%20lp.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Ian James Prukner submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Ian James Prukner was first registered in 2007 with PFS Investments Inc.. In accordance with the terms of the AWC, FINRA imposed upon Pae a $10,000 fine and a 24-month suspension from associating with any FINRA member in all capacities. As alleged in part in the "Overview" of the AWC:
Between April 2021 and August 2022, Prukner engaged in an outside business activity (OBA) as an owner and co-CEO of a company that engaged in e-commerce and lead generation without providing prior written notice to PFSI. As a result, Prukner violated FINRA Rules 3270 and 2010.
FINRA Fines and Suspends Rep for E-Commerce and Lead Generation OBAs
In the Matter of Melton Weaver III, Respondent (FINRA AWC 2022074939303)
https://www.finra.org/sites/default/files/fda_documents/2022074939303
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For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Melton Weaver III ( submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Melton Weaver III was first registered in 2007 with PFS Investments Inc. In accordance with the terms of the AWC, FINRA imposed upon Weaver a $10,000 fine and a 24-month suspension from associating with any FINRA member in all capacities. As alleged in part in the "Overview" of the AWC:
Between March 2021 and March 2023, Weaver engaged in an outside business activity (OBA) as an owner and CFO of a company that engaged in e-commerce and lead generation without providing prior written notice to PFSI. As a result, Weaver violated FINRA Rules 3270 and 2010.
FINRA Fines and Suspends Rep for Electronic Signatures
In the Matter of Jacob Pae, Respondent (FINRA AWC 2022075705601)
https://www.finra.org/sites/default/files/fda_documents/2022075705601
%20Jacob%20Pae%20CRD%207059044%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Jacob Pae submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Jacob Pae was first registered in 2019 with Northwestern Mutual Investment Services, LLC. In accordance with the terms of the AWC, FINRA imposed upon Pae a $5,000 fine and a 45-calendar-day suspension from associating with any FINRA member in all capacities. As alleged in part in the AWC:
On August 24, 2021, and November 18, 2021, Pae received ACH Authorization Agreements concerning brokerage accounts executed by Northwestern customers that contained clerical errors and required re-execution. Rather than sending the customers corrected ACH Authorization Agreements to re-execute, Pae copied the electronic signatures from the original agreements and pasted them to the corrected ACH Authorization Agreements without the customers’ consent. Subsequently, Pae submitted the two documents containing the forged customer signatures to Northwestern for review and approval.
By forging customer signatures, Pae violated FINRA Rule 2010. In addition, by causing Northwestern to preserve inaccurate records, Pae violated FINRA Rules 4511 and 2010.
FINRA Fines and Suspends Rep for Inaccurate Customer Information
In the Matter of Ronald Morse, Respondent (FINRA AWC 2019063686207)
https://www.finra.org/sites/default/files/fda_documents/2019063686207
%20Ronald%20Morse%20CRD%20341008%20AWC%20lp.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Ronald Morse submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Ronald Morse was first registered in 1971, and by 2002, he was registered with David Lerner Associates, Inc. In accordance with the terms of the AWC, FINRA imposed upon Morse a $5,000 fine and a 20-business-day suspension from associating with any FINRA member in all capacities. As alleged in part in the AWC:
Morse works as a sales assistant to a producing broker at DLA. In April 2019, a senior customer of that producing broker complained to DLA that information on her customer profile, including her investment objectives, risk tolerance, and liquid net worth, were inaccurate. In May 2019, following communications with the customer, Morse created a revised customer profile document. The revised customer profile document contained some of the changes the customer requested, but was inaccurate with respect to aspects of the customer’s stated investment needs. After revising the customer profile document, Morse affixed the customer’s signature without her permission.
By falsifying a customer profile document and forging the customer’s signature, Morse violated FINRA Rule 2010. In addition, by causing DLA to maintain inaccurate books and records, Morse violated FINRA Rules 4511 and 2010.
FINRA Fines and Suspends Rep for Changed Rep Codes
In the Matter of Michael MacLean, Respondent (FINRA AWC 2021069200301)
https://www.finra.org/sites/default/files/fda_documents/2021069200301
%20Michael%20MacLean%20CRD%205457640%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Michael MacLean submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Michael MacLean was first registered in 2008 with Morgan Stanley. In accordance with the terms of the AWC, FINRA imposed upon Morse a $5,000 fine and a 45-calendar-day suspension from associating with any FINRA member in all capacities. As alleged in part in the AWC:
From October 2016 through April 2020, MacLean placed 366 trades in accounts that were covered by the agreement using a representative code other than the one he should have used. Specifically, although Morgan Stanley's system prepopulated the trades with the applicable joint representative code, MacLean changed the code for the 366 trades to a different representative code that he shared only with the other representative. MacLean changed the codes because he mistakenly believed that his agreement with the retired representative did not apply to new assets added to accounts subject to the agreement. The firm's trade confirmations for the 366 trades inaccurately reflected the representative code that MacLean shared only with the other active representative. MacLean's actions resulted in his receiving higher commissions from the 366 trades than what he was entitled to receive pursuant to the agreement. ln November 2021 , Morgan Stanley reimbursed the retired representative.
By causing Morgan Stanley to maintain inaccurate trade confirmations, MacLean violated FINRA Rules 4511 and 2010.
FINRA Censures and Fines TD Private Client Wealth LLC for Supervision of Correspondence and Communications
In the Matter of TD Private Client Wealth LLC, Respondent (FINRA AWC 2019064801101)
https://www.finra.org/sites/default/files/fda_documents/2019064801101
%20TD%20Private%20Client%20Wealth%20LLC%20CRD%20164484
%20AWC%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, TD Private Client Wealth LLC submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that TD Private Client Wealth LLC has been a FINRA member since 2013 with about 585 registered representatives at 40 branches. In accordance with the terms of the AWC, FINRA imposed upon TD Private Client Wealth LLC a Censure, $600,000 fine, and undertakings to certify compliance with the issues cited. As alleged in part in the "Overview" of the AWC [Ed: footnote omitted]:
From February 2013 through July 2022, TDPCW failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with the firm's obligation to review correspondence and internal communications. As a result, the firm failed to review approximately 3.5 million emails related to 691 employee email accounts. Accordingly, the firm violated NASD Rule 3010 and FINRA Rules 3110 and 2010.
FINRA Censures and Fines Cowen for NMS Reports and Supervision
In the Matter of Cowen and Company(in its own right and as successor-in-interest to Cowen Prime Services LLC), Respondent (FINRA AWC 2021071022201)
https://www.finra.org/sites/default/files/fda_documents/2021071022201
%20Cowen%20and%20Company%20CRD%207616%20AWC
%20vr.pdf
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Cowen and Company submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted The AWC asserts that Cowen has been a FINRA member since 1978 with about 800 registered representatives at 19 branches. In accordance with the terms of the AWC, FINRA imposed upon Cowen a Censure and $275,000 fine. As alleged in part in the "Overview" of the AWC [Ed: footnote omitted]:
Between May 2020 and July 2023, Cowen Prime and Cowen published quarterly reports on their handling of customers’ orders in National Market System (NMS) securities that failed to disclose required information, provided inaccurate and incomplete information, or were not timely published. Therefore, Respondent violated Rule 606(a) of Regulation NMS and FINRA Rule 2010.
Between May 2020 and October 2023, Cowen Prime and Cowen’s supervisory systems, including written supervisory procedures (WSPs), were not reasonably designed to achieve compliance with Rule 606. Therefore, Respondent violated FINRA Rules 3110 and 2010.
FINRA Arbitration Panel Grants Motion for Stipulated Award
In the Matter of the Arbitration Between NYLife Securities LLC and
New York Life Insurance Company, Claimants, v. James Myers, Respondent (FINRA Arbitration Award 23-01962)
https://www.finra.org/sites/default/files/aao_documents/23-01962.pdf
In a FINRA Arbitration Statement of Claim filed in July 2019 by NYLife Securities LLC and New York Life Insurance Company, Claimants asserted "breach of contract." The FINRA Arbitration Award asserts that:
[T]he cause of action related to advancement commissions and other compensation made to the Respondent pursuant to his agency contract which were subsequently reversed, resulting in a negative ledger balance. Upon his resignation from Claimants, the Respondent’s negative ledger balance became a debt due and owing to the Claimants. Claimants asserted the total amount due was $170,765.43, plus interest from the date of Respondent’s resignation and attorney’s fees and costs incurred to collect the debt.
In the Statement of Answer, Respondent acknowledged the debt but stated that he could not repay the Claimants at this time.
Claimants sought not less than $170,765.43 in damages plus interest, fees, and costs. Respondent Myers did not file a Submission Agreement and did not request any relief. In November 2023, the parties filed a Motion for Entry of a Stipulated Award, which the FINRA Arbitration Panel granted. The Panel awarded to New York Life $85,000 subject to a payment schedule of $2,500 per month beginning on December 1, 2023, and extending to July 1, 2024; and, thereafter, calling for a $65,000 final payment on August 1, 2024. Interest will not accumulate provided full payment is timely made, and no fees or costs are incurred.
Bill Singer's Comment: Clients in Respondent Myers position often ask a lawyer what's the best that they can expect if they are unable to fully pay off advances upon demand. In Myers' settlement, it appears that the Respondents compromised their demand for about $171,000 in damages to $85,000 payable over nine months with a final balloon payment. Respondent Myers appeared pro se and may well have handled the settlement negotiations on his own. If he is able to honor his payment obligations, then his efforts resulted in compromising the full amount purportedly owen to about 50% of what was sought AND he also avoided incurring legal fees. The ultimate outcome of his case is not what was agreed to in the Stipulated Award but dependent upon Myers' ability to timely pay the eight months of payments and then pay the final balloon payment. Time will tell how this all finally resolves.
In some cases involving unpaid advances, bankruptcy may be an option; in other cases, it may simply be a matter of scheduling out payments over a period of time that may allow for settlement. Even when a schedule is agreed to, however, circumstances may arise that thwart the best of intentions. In such cases, the parties may agree to extensions of times or further work-outs. In other cases, the unpaid balance may become the subject of further litigation.