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.
Dhulsini Hemani De Zoysa
AWC/2007010562701

De Zoysa published research reports in which she made false, exaggerated, unwarranted or misleading statements, and published the reports, which she knew were false or misleading. De Zoysa was involved in a romantic relationship with an executive of a company within her coverage area and failed to disclose the relationship, which created an actual, material conflict of interest. In contravention of her firm’s directive, De Zoysa created and deleted documents on her laptop computer after commencement of the firm’s internal investigation. 


Dhulsini Hemani De Zoysa: Fined $10,000; Barred in any capacity requiring the Research Analyst Series 86 (Analysis) and/or Series 87 (Regulatory Administration and Best Practices); Suspended 12 months in all capacities.

Bill Singer's Comment
Can't wait to see the movie version of this -- or maybe I'll just wait for the cheaper DVD release. If there is one concern that I have with this case it's that Wall Street and its regulators seem to have a double-standard sometimes when it comes to the private lives of its male and female employees.  We need to be very careful that we view as equally troubling the dalliances that men have with strippers and female subordinates.  While I have no intent to detract from whatever the substantive conflict was that De Zoysa created, I wonder how many males are disclosing similar "romantic" relationships.  What does trouble me with this case is that she was charged with failing to disclose her romantic relationship with a covered company's CEO/Chair in 19 reports, but only four of those reports were published during her three-month relationship.  The subsequent 15 reports were issued no earlier than 2 months and in some cases over a year after the break-up.  That doesn't make sense to me.
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