According to FINRA, Ibrahim Ethem Kurtulus was fined $2,500 and suspended from association with any FINRA member in all capacities for two months for holding a beneficial interest in two brokerage accounts in his wife's name maintained at other member firms without obtaining prior written consent from his member firm.

The findings revealed that Kurtulus held beneficial interests in two brokerage accounts at other member firms without proper disclosure and approval. The accounts were held in his wife's name, but Kurtulus maintained beneficial interests in them—meaning he had some level of financial interest or control over the accounts despite not being the named account holder.

Securities regulations require registered representatives to obtain prior written consent from their employing firms before establishing or maintaining securities accounts at other broker-dealers. This requirement serves several important purposes: it allows firms to supervise representatives' securities transactions, helps identify potential conflicts of interest, enables firms to monitor for insider trading or other prohibited trading activity, and ensures representatives are not engaging in personal trading that conflicts with their duties to customers or their firms.

The requirement applies regardless of whose name appears on the account if the representative has a beneficial interest. Attempting to circumvent disclosure requirements by holding accounts in a spouse's name does not eliminate the obligation to disclose and obtain consent.

In addition to failing to obtain prior written consent for the accounts, Kurtulus submitted a personal activity questionnaire that inaccurately represented that he did not have a beneficial interest in any external investment accounts. This false representation transformed the violation from a failure to disclose into active misrepresentation, demonstrating knowledge of the disclosure requirement and a conscious decision to violate it.

Kurtulus eventually disclosed both accounts to his firm, but this belated disclosure came only after the violations had occurred. While voluntary disclosure is viewed favorably in mitigation, it does not erase the underlying violations or the risks created by the period of non-disclosure.

The two-month suspension, in effect from December 1, 2025, through January 31, 2026, along with the $2,500 fine, reflects the seriousness of maintaining undisclosed outside securities accounts and providing false information on compliance questionnaires.

Investors should understand that registered representatives are subject to ongoing supervision by their firms, including supervision of their personal securities transactions. When representatives maintain undisclosed accounts, they undermine this supervisory framework and may be engaging in activities that create conflicts with their customer obligations.