Based on the parties’ stipulations, the Hearing Panel finds that Respondent violated NASD Rules 3010 and 2110 by failing to supervise the outside business activities and private securities transactions of two registered representatives; and that Respondent violated NASD Rules 3010 and 2110, and FINRA Rule 2010, by failing to establish, maintain, and enforce written supervisory procedures that were reasonably designed to supervise the activities of its registered representatives. As the parties stipulated, Respondent is required to retain a consultant to review its written supervisory procedures, and is fined $100,000. The Hearing Panel finds that Respondent is able to pay the entire amount of the fine, but establishes a payment schedule due to Respondent’s financial condition.
This decision has been appealed.
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