Acting through Lim, the Firm failed to
preserve emails in nonrewritable, non-erasable format;
failed to provide FINRA with notifications of its use of electronic storage media;
provide FINRA with a letter from a third party describing the third party’s undertakings regarding the firm's electronic storage media as specified by Securities and Exchange Commission (SEC) Rule 17a-4; and
evidence the review of all incoming and outgoing email communications with customers.
The firm's written procedures failed to identify locations that regularly conducted the business of effecting securities transactions by soliciting new accounts as branch offices, and failed to address the firm's requirement to conduct internal inspections of these offices.
Investscape, Inc.: Censured, Fined $7,000; and Fined $17,500, jointly and severally with Lim
Richard Michael Lim: Fined $17,500, jointly and severally with Investscape and Suspended 1 year in Supervisory capacity only