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De Minimis Activity is Never an Excuse for Lacking Adequate Supervision
by Howard Haykin
A Baltimore, MD-based firm agreed to pay a $10K fine to settle FINRA charges that it executed municipal securities transactions without having a Municipal Securities Principal at the firm.
FINRA FINDINGS. In this case, the broker-dealer, a FINRA member since 1991, has 54 registered branch offices and 69 registered persons. According to its CRD records, is the firm is engaged in the business as a Municipal Securities Broker.
Between December 2015 and March 2016, the firm executed 5 municipal securities transactions without having a Municipal Securities Principal (Series 53) at the Firm.
Between January 2014 and March 2016, the firm failed to establish and maintain a supervisory system and written procedures reasonably designed to supervise municipal securities transactions. Responsibility for reviewing municipal securities transactions was instead delegated to a principal who did not hold a Municipal Securities Principal license. In addition, Lombard permitted another principal who also was not a Series 53 Principal to review and approve at least 26 municipal securities transactions.
This case was reported in FINRA Disciplinary Actions for June 2018.
For details on this case, go to ... FINRA Disciplinary Actions Online, and refer to Case #2016047661702.
