Frankly, this case disgust me. For some context, read this recent SEC action against a Chinese listed company that made an accounting error that resulted in a few years of erroneous, publicly reported financials. In that Chinese-firm case, the SEC imposed no fine or censure but settled for an Cease-And-Desist.
Why is there a $20,000 fine in this case? The FINRA member firm hired a Third Party Vendor to handle certain mutual fund computations. Omigod! There was a software error!! As if what? That doesn't happen to all of us -- not even FINRA?
Regrettably, PlanMember's customers suffered a $4,000 overcharge as a result of a computer error made by its third party vendor. The entire overcharge was refunded to all customers and we can infer that the member firm took steps to ensure better communications with its vendor. Nonetheless, nothing that happened here was intentional and, I suspect, nothing that the member firm had reasonably done would likely have prevented the glitch. These things just happen.
I can think of few pronouncements that issue from FINRA and other hypocritical regulators that are more obnoxious and absurd than this: The Firm's decision to outsource its breakpoint determinations to a third party did not relieve the firm of its ultimate responsibility for the outsourced activity. I mean, really, give me a break!