NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

LPL Financial Corporation nka LPL Financial LLC
AWC/2009016570001

LPL failed to enforce its supervisory system and written supervisory procedures relating to the review of electronic communications in certain branch locations. Approximately 3 million emails firm financial advisors transmitted and received from numerous bank branch locations related to one bank program were not processed through the Office of Supervisory Jurisdiction Review Tool (ORT) due to a technology problem concerning the interface between one bank program’s email system and the firm’s ORT; therefore, those emails were not subject to supervisory review by firm managers and principals. The firm’s ORT flagged for supervisory review emails financial advisors in a branch office transmitted and received, but a branch manager or principal never reviewed them.

LPL Financial Corporation nka LPL Financial LLC : Censured; Fined $100,000

Tags: Electronic Communications  Email