FINRA Sanctions TPEG Securities for Failure to Timely File PPMs
According to the Financial Industry Regulatory Authority (FINRA)on June 4, the regulator issued a Letter of Acceptance Waiver and Consent (AWC) to TPEG Securities, LLC (CRD #146726, Southlake, Texas) in which the firm was reportedly censured and fined $25,000. The firm reportedly consented to the sanctions.
FINRA alleged the firm engaged in private placement offerings in which it failed to timely file with FINRA the private placement memorandum, term sheet, or other offering documents.
The findings stated that the firm allegedly filed these documents from between three days to more than one year after the required filing date, preventing FINRA’s ability to timely review the offerings.
The findings also stated that the firm’s supervisory system and WSPs were purportedly not reasonably designed to achieve compliance with FINRA rules. Although the firm’s primary business involved private placements, and the firm conducted numerous private placement offerings every year, it allegedly failed to have a system in place to reasonably supervise its filing obligation.
Further, the firm also did not reportedly designate any individual with supervisory responsibility for Rule 5123 filings. In addition, the WSPs allegedly failed to provide guidance regarding the date that triggered the filing requirement. The WSPs also purportedly provided no definition of the date that triggered the filing requirement and failed to correctly define the first sale date for purposes of the filings.
For more information on FINRA’s findings please see FINRA Case #2017053051001.
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