than four years, the firm
relied exclusively on electronic storage media to preserve its
communications. The firmís electronic storage media system was
deficient because such
communications could be deleted from the system prior to being
preserved in the requisite
non-rewritable, non-erasable format.
In contravention of its WSPs,
the firm permitted Conyers, its president and CCO, to use a
personal email address, through
his handheld communication device, to send and receive
communications, which were not captured by the firmís system and
thus were not retained
nor reviewed by the firm, unless they were sent to or from a
firm-provided email address.
The firm failed to evidence its
review of its business-related
electronic communications, in violation of its WSPs.
Through Conyers, the Firm permitted non-registered persons to act in
a capacity requiring
registration as a principal; and permitted non-registered persons
to accept or approve a total of more than 300 new customer
accounts. As a result, the firm failed to maintain records signed by a principal
who had accepted or
approved new customer accounts.
First Bermuda Securities (BVI) Ltd.: Censured; Fined $10,000 jt/sev with Conyers; Fined additional $40,000
Jeffrey Gerald Conyers: Censured; Fined $10,000 jt/sev with First Bermuda;