According to FINRA, Amy M. Greenberg was assessed a deferred fine of $5,000 and suspended for five months in all capacities for willfully failing to timely amend her Form U4 to disclose an unsatisfied federal tax lien for $56,937.77.

The Internal Revenue Service mailed notice of the tax lien to Greenberg's residential address. Although she was required to disclose the tax lien via filing an amended Form U4 within 30 days of receiving notice, she failed to amend her Form U4 until almost four years later.

Form U4 disclosure requirements serve critical investor protection purposes. Financial difficulties, including significant unsatisfied tax liens, can create pressures that may lead registered persons to engage in misconduct such as borrowing from customers, conversion, or recommending unsuitable high-commission products to generate income. Firms need to know about such financial issues to assess fitness and implement appropriate supervision.

Investors and firms rely on the accuracy and completeness of Form U4 disclosures when evaluating registered persons. A federal tax lien exceeding $56,000 is material information that should have been disclosed promptly. The nearly four-year delay in disclosure deprived Greenberg's firm and the public of important information about her financial condition.

The finding that Greenberg's failure was willful means she intentionally failed to disclose the lien, not that she intended to violate securities rules. The willful nature of the non-disclosure makes it particularly serious.

The five-month suspension holds Greenberg accountable for willfully failing to timely disclose a substantial federal tax lien for nearly four years, depriving her firm and regulators of material information about her financial condition.