According to FINRA, Old Slip Capital Management, Inc. was censured and fined $15,000 for failing to maintain accurate records of aggregate indebtedness and net capital.

The firm signed a loan agreement with the Small Business Administration for a $500,000 Economic Injury Disaster Loan (EIDL) but failed to include the loan value when calculating its aggregate indebtedness. This caused the firm to prepare and maintain inaccurate aggregate indebtedness and net capital computations. As a result, the firm filed FOCUS reports that inaccurately stated its aggregate indebtedness, minimum required net capital, and net capital deficiency.

The firm also filed notices with the SEC and FINRA stating that it failed to maintain its minimum required net capital but did not conduct securities business during the deficiency period. However, these notices inaccurately stated the firm's minimum required net capital and understated the firm's net capital deficiency.

Additionally, the firm failed to timely respond to FINRA's requests for information and documents during its investigation. The firm did not provide any documents in response to several items, including emails concerning the EIDL receipt and communications with the SBA. The firm only provided a complete response after FINRA issued a Notice of Suspension.

This case demonstrates the critical importance of accurate recordkeeping in the securities industry. Firms must properly account for all liabilities, including loans from government programs, when calculating net capital requirements. Investors should verify that their brokers are properly capitalized and maintain compliance with regulatory requirements, as net capital deficiencies can indicate financial distress that may affect the firm's ability to serve customers.