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.
September 2009 - View all for this month
Jamik Jamar Ligon (Principal) and Rocco Anthony Mongelli
AWC/2008013653901

Ligon paid Mongelli a $50,000 referral compensation fee when Mongelli referred brokerage customers to Ligon because he was not registered to do business in the states of residence for those referred customers, and Ligon subsequently served as the registered representative for the accounts. 

Jamik Jamar Ligon (Principal): Fined $7,500; Suspended 2 months

Rocco Anthony Mongelli: Fined $10,000; Suspended 3 months

Bill Singer's Comment
This is one of the oldest end-runs in the book. The problem is, this play hasn't worked for decades but folks still seem to think that they have cleverly figured a way to circumvent the registration issue. Well, these two Respondents will have two and three months respectively to figure out what went wrong. The one issue I have with FINRA's sanction is that I don't understand how Mongelli was only fined $10,000 as against the $50,000 fee. If the fee was reversed by Mongelli's broker-dealer, then it would have been helpful for FINRA to spell that out in its monthly report.
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