According to FINRA, Michael Gerard Gravelyn was barred from association with any FINRA member in all capacities for refusing to produce information and documents requested by FINRA.
FINRA's investigation arose from a Form U5 filed by Gravelyn's member firm. The Form U5 disclosed that Gravelyn had been permitted to resign after a review of his business practices revealed that he had violated company policy. When FINRA requested information and documents to investigate the circumstances that led to the Form U5 filing, Gravelyn refused to provide them.
The refusal to cooperate with FINRA investigations is treated as one of the most serious violations a registered person can commit. FINRA's ability to protect investors depends on its ability to obtain information from registered persons who are under investigation. The securities industry operates under a self-regulatory model where FINRA, as the self-regulatory organization, conducts examinations and investigations to enforce compliance with securities laws and regulations. Registered persons agree to cooperate with these investigations as a condition of their registration.
Form U5 is the uniform termination notice that firms must file when a registered person's employment ends. When a Form U5 indicates that a person resigned after violating company policies, it raises red flags that warrant investigation to determine whether securities laws or regulations were violated and whether the person poses a risk to investors. By refusing to cooperate with FINRA's investigation, Gravelyn prevented FINRA from determining the full facts and circumstances of his conduct.
A bar from the securities industry means that Gravelyn cannot work in any capacity for any FINRA member firm. Investors can check the employment history and disciplinary record of any registered person through FINRA's BrokerCheck system, which includes information about terminations and bars. This public disclosure helps investors make informed decisions about who they trust with their investments.