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FINRA August 2015 Disciplinary Actions: Part III

September 17, 2015

By The Frankowski Firm, LLC

Edward D. Jones & Co., L.P. of St. Louis, Missouri submitted a letter of acceptance, waiver, and consent that censured the firm and fined it $10,000. FINRA found that it failed to report the right trade execution time for transactions in TRACE-eligible securitized products to TRACE and failed to show the right execution time on the memoranda of brokerage orders.

Julian Luis Alfonso of Miami, Florida submitted a letter of acceptance, waiver, and consent that barred him from being associated with any FINRA member in any principal or supervisory capacity for a month and mandated to requalify by exam as a Financial and Operations Principal ("FINOP") before doing so. As a result of his financial status, Alfonso was not given a monetary fine. FINRA found that Alfonso failed to enforce his member firm's written supervisory procedures pertaining to financial controls as well as books and records. As a result, the firm had several incorrect entries in its books and records. Alfonso also allowed the firm to engage in securities business while it was net capital deficient. Finally, Alfonso, the firm's Chief Compliance Officer, failed to alert its FINOP that the firm entered into a settlement with FINRA for a $25,000 fine, which should have been accrued as a liability.

Garyn Ian Angel of Port Richey, Florida submitted a letter of acceptance, waiver, and consent in which he was fined $7,500 and banned from associating with any FINRA member in any capacity for four months. FINRA found that Angel engaged in two private securities transactions without giving prior written notice to his member firms. He also settled a client's complaint pertaining to an investment without telling his present or former firms.

Gregory Howard Bray of St. Louis, Missouri submitted a letter of acceptance, waiver, and consent that fined him $7,500 and banned him from associating with any FINRA member in any principal capacity for six weeks. FINRA found that Bray failed to adequately supervise a registered principal, who was the member firm's CEO and COO, relating to the principal's sales of particular complex products and recommendations of Class A mutual fund shares. Bray further failed to ensure that the principal understood the complex products he was selling to clients. Bray himself did not understand the risks of some of the complex products and could not have had any reason to know that the principal understood them either or that the principal's recommendations were suitable.