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.
John Christopher Nori (Supervisor)
AWC/2008012093801
Nori denied to NYSE Regulation examiners that the branch office he supervised employed non-registered cold-callers and that they used telemarketing scripts when, in fact, there were interns at the branch office engaged in those activities. In an attempt to obfuscate the facts and mislead the examiners, Nori instructed his staff at the branch office that, if asked, the employees were to tell the examiners that there were no approved interns employed at the branch office. While either possessing personal knowledge to the contrary or after learning information to the contrary, Nori failed to fully and accurately disclose to the examiners that his member firm employed non-registered cold-callers at a branch office.
John Christopher Nori (Supervisor): Fined $5,000; Suspended 3 months in all capacities; Concurrently Suspended 6 months in any Supervisory capacity only; Required to Requalify as a Series 9 and 10 prior to beginning any supervisory position following his suspensions.
Bill Singer's Comment
Unregistered cold callers. Telemarketing scripts. Shades of the old boiler-room days of the '80s and '90s. Given the allegations, Nori is lucky that he got off with only a $5,000 fine, a 3-month plenary suspension, and a Requal.  Frankly, he could have been barred as a Supervisor and hit with a far longer suspension in all capacities. Either really great lawyering or FINRA didn't disclose some mitigating facts.
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