According to FINRA, Kyle Joon Kim of Dulles, Virginia was fined $5,000 and suspended from association with any FINRA member in all capacities for three months for participating in an outside business activity without providing prior notice to his member firm.

Kim and two other persons formed an informal partnership to build and sell residential properties. Kim formed a limited liability company to support the partnership, serving as managing member and controlling the company's bank account.

Kim's anticipated role included helping decide which parcels to develop, how they would be developed, working with subcontractors, and other project logistics. After pausing for the COVID-19 pandemic, Kim and his partners resumed planning.

Kim also arranged for two firm customers to provide a total of $90,000 to help finance the projects. This involvement of firm customers in his outside business created additional concerns beyond the mere failure to disclose.

Additionally, Kim did not provide responses to specific questions on his firm's annual compliance questionnaires, further obscuring his outside activities from the firm's oversight.

The requirement to disclose outside business activities serves multiple purposes: it allows firms to evaluate potential conflicts of interest, assess whether the activity might harm the firm's reputation, and determine whether firm customers might be at risk. When customers invest in a broker's outside ventures, as happened here, the potential for conflicts is significant.

The suspension is in effect from May 19 through August 18, 2025.

Investors who provided funds for Kim's real estate projects should understand this investment was made without firm oversight, and they may wish to review their arrangements carefully.