NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.
Joe Farnham Moore Jr. (Principal) AWC/2007008264101
Acting through Moore, his firm failed to
establish and maintain a system to supervise a registered representative’s activities and to adequately investigate the representative’s disciplinary background. The RR's' disciplinary history should have alerted the firm to the fact that the representative required heightened supervision, but the firm failed to establish procedures addressing heightened supervision and failed to implement the representative’s heightened supervision; and
supervise the representative by failing to ensure that new account forms that he submitted contained the required information.
Moore falsely represented to the Texas State Securities Board that the representative had not engaged in a securities business in Texas prior to the execution of an undertaking that his firm agreed to and that Moore signed for allowing the representative’s registration in Texas. Also, Moore unreasonably delegated some of his supervisory responsibilities to an inexperienced, untrained and unregistered subordinate, and failed to review firm records to learn about the extent of the representative’s activities in his customer’s accounts.
Joe Farnham Moore Jr. (Principal): Fined $10,000; Suspended 2 years