Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
RESEARCH and ADVERTISING
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
RBC Capital Markets Corporation
OS/2005002206701

RBC Capital Markets Corp allowed associated persons to function as research analysts without having Series 86 or 87 research analyst registrations. The unregistered analysts published more than 3,500 research reports, and published more than 400 research reports after FINRA informed the firm that it had made a preliminary determination to recommend disciplinary action be initiated (one of the cited reports was published 7 months after the issuance of the Wells Notice) against the firm for its failure to appropriately register its research analysts (the Wells Notice). 

RBC Capital Markets Corporation: Censured; Fined $150,000
Bill Singer's Comment
This one sort of caught my attention. First of all, it involves RBC,which many of us have long held as a fairly conservative organization not known for non-compliant behavior -- yeah, coming from me of all folks, that's is very high praise. Second, allowing unregistered analysts to pen thousands of research reports is a fairly big goof bordering on epic proportions; all the more so for a somewhat staid firm like RBC. Third, after the Ref throws the flag on the field, you then go out and fail to catch a further 400 reports authored by mere associated persons -- and you let the last report get published as far as 7 months after the notice?
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