According to FINRA, Piper Sandler & Co. was censured and fined $25,000 on July 18, 2024, for permitting an associated person to engage in activities requiring qualification as a municipal securities representative when that individual was not qualified to act in that capacity.
In connection with a municipal bond offering for which the firm acted as underwriter, the associated person provided advice and represented the firm in meetings or calls with the issuer and municipal advisor. These activities required the person to be registered as a municipal securities representative, but the individual lacked the necessary qualifications.
The firm's supervisory systems and written supervisory procedures were not reasonably designed to ensure compliance with MSRB rules relating to qualification requirements. While the firm's procedures tasked supervisors with ensuring that associated persons maintained the registrations required for their job functions and did not engage in activities inconsistent with their qualifications, the procedures did not provide supervisors with guidance on how to carry out these responsibilities. Furthermore, the firm did not provide supervisors access to systems reflecting associated persons' testing, licensing, or registration information.
Following this violation, the firm established a supervisory system for monitoring the registrations of its associated persons and adopted written supervisory procedures requiring compliance to provide supervisors with monthly updates on associated persons' testing, licensing, and qualification status. This case illustrates the importance of ensuring that individuals performing securities-related activities have the appropriate qualifications and registrations. Investors can verify the registrations and qualifications of individuals through FINRA's BrokerCheck system.