From May 2021 through December 2023, Greenbird Capital did not establish, maintain, and enforce a system, including written procedures, reasonably designed to supervise the firm’s solicitations of private placements and the telemarketing activities of its registered representatives with respect to the national do-not-call list and calls during prohibited times. Therefore, the firm violated FINRA Rules 3110, 3230(d) and 2010, and is censured and fined $50,000.

In February 2023, while associated with Commonwealth Financial Network, Smith certified to the State of New York that he had personally completed the continuing education (CE) required to renew his state insurance license, when, in fact, another person had completed that CE on his behalf. Therefore, Smith violated FINRA Rule 2010.