Proceeding Number 2011028502101
Hearing Panel Decision in Department of Enforcement v. North Woodward Financial Corp. and Douglas A. Troszak
May 16, 2014
Respondents North Woodward Financial Corp. and Douglas A. Troszak (1) failed to respond in a timely manner to FINRA requests for information and denied FINRA access to the firm’s premises in connection with a scheduled cycle examination (and Troszak failed to respond completely to a separate request for information), in violation of FINRA Rules 8210 and 2010; (2) failed to establish and maintain adequate written supervisory procedures, in violation of NASD Rule 3010 and FINRA Rule 2010; (3) failed to prepare required reports and certifications, in violation of NASD Rule 3012, and FINRA Rules 3130 and 2010; (4) failed to establish and implement appropriate AML procedures, in violation of NASD Rule 3011(b), and FINRA Rules 3310(b) and 2010; (5) failed to conduct an independent AML test in a timely manner, in violation of FINRA Rules 3310(c) and 2010; and (6) failed to provide customers with an adequate privacy notice, in violation of Regulation S-P, NASD Rule 2110, and FINRA Rule 2010.
North Woodward is suspended from FINRA membership for one year for its failures to comply timely with FINRA’s Rule 8210 requests; suspended from FINRA membership for 30 business days for its supervisory violations, and fined a total of $25,000 ($10,000 for its supervisory violations, $5,000 for its failure to timely update Troszak’s Form U4, and $10,000 for its failure to provide customers with an adequate privacy notice).
Troszak is barred from associating with any member firm in all capacities for his failures to comply with FINRA’s Rule 8210 requests. In addition, Troszak is barred from associating with any member firm in any principal or supervisory capacity for his supervisory violations. In addition, Respondents are jointly and severally ordered to pay costs.
This decision has been appealed or called for review. While the appeal or call for review is pending, the findings and sanctions imposed in this decision are subject to review and modification by FINRA or the SEC.
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