Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2009
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.
Charles James Moni
AWC/2006005007601
Moni recommended concentrated positions in the security of a clinical-stage drug development company to customers of his member firm. The concentrated positions were unsuitable for Moni’s customers in light of their financial profile, personal circumstances and limited ability to withstand loss. 
Charles James Moni: Fined $10,000; Suspended 3 months
Bill Singer's Comment
Sure -- you understand what happened here. The broker was all over this deal. Possibly thought that this was the next cure for cancer or some wonder drug. Maybe even figured that he was going to hit this one out of the ballpark and be a hero to his clients. All well and fine. Only problem is that you're going to have a very tough time convincing FINRA that all/most/a large number of your clients should be loaded up with such a speculative stock--regardless of its prospects or your motives. How tough a time? Oh, about $10,000 worth and toss in three-months of downtime.
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