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ARTICLE · 15 JUNE 2021

Firm Settles FINRA Charges For OBA Disclosure Failures

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A firm settled FINRA charges for failing to adequately review one of its registered representative's outside business activity disclosures.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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A firm settled FINRA charges for failing to adequately review one of its registered representative's outside business activity ("OBA") disclosures.

In a Letter of Acceptance, Waiver and Consent, FINRA found that the firm failed to evaluate whether the registered representative's reported OBA constituted securities transactions that should have been considered outside securities activity. The registered representative's OBA included the sale of a company involved in "structured cash flow" activities through the purchase of pensions at a discount and the resale of portions of such pensions to investors. The company ceased its business in April 2018 and owed upwards of $300 million to investors in unpaid payments.

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