From January 2020 to May 2023, Moody Capital failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with FINRA rules governing outside business activities (OBAs) and outside securities accounts, in violation of FINRA Rules 3110 and 2010. Additionally, from January 2020 to December 2022, the firm did not evaluate 23 OBAs disclosed by registered representatives, in violation of FINRA Rules 3270.01 and 2010.

From November 2022 through November 2025, IFP failed to reasonably supervise recommendations of Class A mutual funds and Unit Investment Trusts. The firm relied on an automated surveillance system to identify transactions for review. However, throughout the period, the firm’s automated surveillance system failed to generate alerts and the firm had no other system in place. Therefore, IFP violated Rule 15l-1 of the Securities Exchange Act of 1934 (Reg BI) and FINRA Rules 3110 and 2010 and is censured and fined $100,000.