Neither CCO Nor FINOP Had License
FINRA fined and censured an institutional broker-dealer for failing to register and identify its Chief Compliance Officer and Financial Operations Principal.
The persons serving as CCO and FINOP were not properly registered. The firm compounded the violation by identifying other individuals on the Form BD that did not actually perform the required functions. FINRA also cites the firm for failing to establish risk controls to operate its market access business, including pre-trade controls designed to limit credit and capital thresholds.
So, your CCO doesn’t have his Series 24, and your FINOP doesn’t have her Series 27? What do you do? Name somebody (anybody) that has the license whether or not they perform the function? No. A better idea would be to go to FINRA and get some time to allow the officers to sit for the tests. In regulatory compliance, two wrongs don’t make it right; they make it more wrong.
Read full Letter of AWC here.