Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2009
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.
Raymond Lee Noragon (Principal)
OS/2007007321102
Noragon failed to cause his firm to conduct an annual compliance meeting, and failed to ensure that Offices of Supervisory Jurisdiction (OSJ) and non-OSJ branch offices were examined and the examinations documented. Noragan approved his member firm’s participation as an underwriter in securities offerings without ensuring that the prospectuses used in connection with the offerings contained adequate disclosures and were not materially misleading
Raymond Lee Noragon (Principal): Fined $25,000; Suspended 6 months in Principal Capacity only.
Bill Singer's Comment
As noted earlier, failure to supervise cases (while not rare) aren't that common and typically worth including in my monthly reviews. Noragon failed to conduct the annual compliance meeting -- perhaps the first item on FINRA's checklist of things that Principals didn't do that we will charge them for not doing.  Probably the second thing on that gotcha list is the failure to examine OSJs and offices and document same.
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