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.

Intermountain Financial Services, Inc. and Kent Duane Sweat (Principal)
OS/2008011579401

Acting through Sweat, the Firm failed to

• enforce its written supervisory procedures pertaining to its annual compliance meeting, branch office inspections, outside business activities, outside securities accounts, Regulation SP, hiring practices and the use of personal computers; and
• maintain records of its Firm Element Continuing Education Needs Analysis and Written Training Plan for multiple years, and
• maintain continuing education (CE) records to evidence that the firm’s representatives participated in the Firm Element CE program during one year.

Sweat and the firm failed to maintain copies of registered representatives’ incoming and outgoing correspondence with the public relating to its securities business, and failed to maintain evidence of review as NASD rules and firm procedures required.

The Firm failed to implement

• procedures concerning the capturing, preservation, maintenance and storage of all original and copied communications the firm received and sent;
• a written anti-money laundering (AML) compliance program reasonably designed to achieve the firm’s compliance with the laws, rules and regulations to which it was subject; and 
• its AML procedures by failing to provide AML training in a manner specified in its written AML program, and did not properly update its AML compliance officer contact information as required.

Intermountain Financial Services, Inc.:  Censured; Fined $12,750

Kent Duane Sweat: Fined $7,500; Suspended in Principal Capacity only for 5 business days 

Tags: WSP  Electronic Communications  Email  AML