Raymond James & Associates, Inc. (CRD #705, St. Petersburg, Florida) submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured, fined $27,500 and required to revise its written supervisory procedures (“WSPs”) regarding compliance with NASD Rule 2440 and IM-2440. See FINRA Case #2009017412501.
Without admitting or denying the findings, Raymond James consented to the described sanctions and to the entry of findings that in transactions, it sold/bought corporate bonds to/from customers and failed to sell/buy such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each bond at the time of the transaction, the expense involved and that the firm was entitled to a profit. FINRA also found that Raymond James’ supervisory system failed to provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules concerning compliance with NASD Rule 2440 and IM-2440. FINRA further found that in transactions in TRACE-eligible securities for or with a customer, the firm failed to use reasonable diligence to ascertain the best inter-dealer market, and failed to buy/sell in such market so that the resultant prices to its customers were as favorable as possible under prevailing market conditions.
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