The SEC fined and permanently barred a former broker-dealer chief compliance officer for violating a prior 5-year bar by consulting with the BD on FINOP matters including financial statements and FOCUS filings. The SEC accuses the respondent from executing a consulting agreement on the day after he resigned to comply with the prior bar. According to the SEC, the respondent “continued to run the day-to-day operations” for the next 3 years and maintained a BD email account.
OUR TAKE: There is a special place in the basement of the SEC Enforcement Division with wall photos of recidivists. The SEC staff will show no quarter to those that violate enforcement settlements.