J.P. Morgan Securities LLC (CRD #79, New York, New York) submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $125,000.
Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings that it permitted managing directors in its U.S. Investment Banking Division to perform functions requiring a Series 79 Limited Representative-Investment Banking registration while they were not registered with FINRA in that capacity. The findings stated that all the individuals engaged in activities requiring Series 79 registration including, inter alia, working with the firm’s investment banking teams to, among other things, advise on potential investment-banking transactions. The findings also stated that the U.S. Investment Banking Division’ WSPs pertaining to registration in effect required that all employees take all applicable licensing exams promptly. The firm’s supervisors were required to periodically review quarterly reports to confirm that all team members hold appropriate licenses and are properly registered in each state in which they are conducting investment-banking business.
The firm knew that the managing directors needed to obtain a Series 79 registration when they joined the firm, but failed to ensure compliance with the registration rules. Significantly, the firm did not require one of the managing directors to take the Series 79 licensing examination until after FINRA started inquiring about his registration status, which was some 10 months after FINRA denied the firm’s request for a registration waiver on the managing director’s behalf.
This information which is publicly available on FINRA’s website has been provided by The White Law Group, LLC.
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