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.
Matthew Edward O’Callaghan
AWC/2007009462302
O'Callaghan improperly priced various corporate bond positions in his proprietary trading book to improve the profit and loss totals reported in his book. His member firm became aware of the mismarkings during a routine reconciliation of his positions for daily mark-to-market purposes. The mismarkings resulted in his firm recording inaccurate prices for corporate bonds on its books and records. 
Matthew Edward O’Callaghan: Censured; Fined $10,000; Suspended 18 months in all capacities
Bill Singer's Comment
As noted earlier, Bravo! We are simply seeing more and more reported FINRA cases that note in-house compliance staff's efforts to detect and correct violations. Again, I would still like to see more commentary from FINRA as to how the member firm detected the improper pricing.
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