BD Fined for WSPs With No Mention of Reg BI

The firm did not respond to a request for comment. It consented to FINRA’s findings without admitting or denying them.

No Supervisory System for Reg BI

Since June 30, 2020, JVM Securities “has failed to establish and maintain” a supervisory system, including written supervisory procedures, “reasonably designed to achieve compliance” with Reg BI.

For instance, “one version of the WSPs delegated responsibility to a ‘Reg BI principal,’ but did not identify the principal,” the order states.

Also, the firm’s current WSPs “fail to detail the supervisory steps and reviews that should be undertaken by the principal responsible for supervising compliance with Reg BI — including the frequency of those reviews or how the reviews should be documented,” FINRA said.

Form CRS Failures

From June 30, 2020, to July 18, 2023, JVM Securities “also failed to establish and maintain a supervisory system, including WSPs, reasonably designed to achieve compliance” with its Form CRS obligations.

“Until March 1, 2022, JVM Securities’ WSPs contained no reference to Form CRS,” according to FINRA.

Until the firm adopted revised WSPs on July 19, 2023, the WSPs “were not tailored to the firm’s business and did not prescribe procedures for complying with the firm’s Form CRS obligations.”