One of my ongoing complaints about FINRA is that it does not post the underlying AWC on its website (in contradistinction to the practice at NYSE). As such, you need to contact the SRO to obtain a copy of the AWC if you have any substantive questions. FINRA is pretty good about responding to such requests, but that's beside the point--it would be far more effective regulation and education to provide the underlying AWCs as a link in each monthly case.

Davis is puzzling -- if only in the academic sense -- because it's unclear as to exactly what he did that was a violation. If the customer complained about something and was reimbursed to settle the complaint, then that's an undisclosed settlement violation; however, we have no such indication of that situation. If Davis had guaranteed profits to the customer and the reimbursement was a step towards reducing losses, then that's a violation; however, once again, that's not spelled out. If Davis made the payment in violation of his firm's written policies, then that too could be a violation; however, that's not spelled out either.

As such, we appear to have an RR charged with engaging in an act without notifying his firm and then misleading his firm's compliance staff about that act. It's not clear whether the fine and suspension were imposed in consideration that the act was a violation of FINRA/Firm rules and/or that Davis provided inaccurate information to his firm about said act.

Sure, all in all a somewhat academic objection. Still -- you tell me? Is it a violation to offer a commission rebate to public customers?