Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CONTINUING EDUCATION
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.
February 2009 - View all for this month
Kern, Suslow Securities, Inc.
AWC/2007007314701
The Firm failed to develop and implement a customer identification program. The Firmís Checks Received and Forwarded Blotter or an equivalent record was inadequate in that the firm failed to record checks received. The Firm failed to develop and maintain a continuing and current education program for its covered registered persons for one year, in that it failed to develop a written training plan outlining the Firm Element program and failed to maintain records documenting the content and completion of the Firm Element by its covered registered persons. 
Kern, Suslow Securities, Inc.: Censured; Fined $22,500
Bill Singer's Comment
How you can fail to develop/implement a CIP in this day and age is truly puzzling. But okay, maybe they thought they had one or they had one, but FINRA was being too picky. Then of course we have to tip our hat to the Firm for failing to record checks received--now that's quite a feat!  But, okay, maybe they don't get that many checks and the few that came in they simply deposited without maintaing a formal blotter. However, when you add to the two prior charges the failure to develop/maintain a CE program or to maintain a training plan (I mean, geez, you can cut and paste one of those or pay a few bucks to a consultant), you gotta admit that FINRA raise a tad too many "failures" for it all to be coincidental.  
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