As the curtain fell on 2015, FINRA issued four Letters of
Acceptance, Waiver and Consent (AWCs) providing guidance –
and in many cases, pointed internal supervisory control reminders
– in a broad range of broker-dealer activities: theft from
senior citizen customers (Senior Citizen Matter); selling
billions of unregistered microcap shares (Microcap Securities
Matter); filing inaccurate blue sheets with the SEC and FINRA
(Blue Sheet Matter); and unsuitable mutual fund
transactions (Mutual Fund Suitability Matter).
Not only do these AWCs provide a litany of proper internal
controls, but, in the Microcap Securities Matter, they
emphasize that personal accountability is important to FINRA, and,
in the Mutual Fund Suitability Matter, that
self-disclosure may result in a lower fine. How much? FINRA
doesn't say, but the regulator clearly recognized the
firm's cooperation in specific areas, starting with an internal
investigation prior to regulator detection or intervention.
