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.
Moses improperly allowed a branch operations manager of his member
firm to assist him in
answering Firm Element CE proficiency tests by indicating the
correct answer. The firm required all registered persons to complete
an internal, computerbased
Firm Element CE program on an annual basis. The Firm Element CE
consisted of a series of Web-based courses and accompanying
proficiency tests with
courses pre-assigned to registered individuals based upon the
registrations that they held
at the time of assignment.
Steven Tyler Moses: Fined $5,000; Suspended 30 days