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.

James Michael Porrazzo
2007009436401

Porrazzo engaged in an unreported outside business activity with a customer of his member firm, which his firm prohibited. Porrazzo failed to disclose his participation in a horse racing venture on his firm's questionnaires, which requested the disclosure of any outside business activities, because he knew the firm would not approve. Porrazzo used his personal email address to communicate with the customer about the outside business activity, contrary to the firm’s written policies and procedures that required it to monitor incoming and outgoing correspondence to detect violations of firm policies.

James Michael Porrazzo : Fined $15,000; suspended for consecutive terms of 4 months and 15 business days

Tags: Email