According to FINRA, Caroline Mohan was barred from association with any FINRA member in all capacities for refusing to appear for on-the-record testimony requested by FINRA during its review of a Form U5 filing.

The Form U5 was submitted by Mohan's firm stating that she voluntarily resigned while under internal review for potential involvement with undisclosed outside business activities and participation in private securities transactions. These allegations are serious because they suggest Mohan may have engaged in business activities or securities transactions without her firm's knowledge and approval, depriving the firm of the opportunity to supervise these activities and ensure they were appropriate.

Outside business activities (OBAs) are any business activities outside the scope of a representative's relationship with their firm. Representatives must provide written notice to their firms about OBAs so the firm can determine whether the activities present conflicts of interest or create supervision concerns. Private securities transactions—sometimes called "selling away"—involve recommending or selling securities transactions outside the regular course of business with the firm. These transactions must be disclosed to and approved by the firm.

When FINRA sought to investigate the circumstances described in the Form U5, Mohan refused to appear for testimony. This refusal prevented FINRA from determining what activities Mohan engaged in, whether they were properly disclosed, and whether customers were harmed.

Refusing to testify is treated as one of the most serious violations because it directly obstructs FINRA's regulatory function. FINRA's ability to protect investors depends on registered persons cooperating with investigations. When someone refuses to testify, they prevent FINRA from fulfilling its mission and assessing risk to the investing public.

The context makes the refusal particularly concerning. Mohan resigned while under internal review, suggesting the firm discovered problematic conduct. Rather than addressing the allegations through the regulatory process, she refused to provide testimony, preventing any examination of what occurred.

Investors should be aware that outside business activities and private securities transactions conducted without firm approval deprive investors of important protections. Firms cannot supervise activities they do not know about, and investors lose access to firm resources and dispute resolution processes when transactions occur outside normal firm channels. When a representative is barred for refusing to testify about such activities, investors should understand this likely indicates serious underlying problems.