According to FINRA, Sean T. Sullivan was named as a respondent in a FINRA complaint alleging that he placed unauthorized trades in four customers' accounts.
The complaint alleges that Sullivan executed stock purchases totaling $196,754, plus commissions of $2,110, and other costs in customer accounts. He also allegedly executed stock sales totaling $57,398, plus commissions of $522, and other costs. Sullivan allegedly did not communicate with any of the customers before executing the trades. The customers' accounts were not discretionary, and none of the customers authorized Sullivan to exercise discretion in their accounts.
All four customers complained to Sullivan's member firm about the trades. The firm cancelled and reversed the trades for three customers. The fourth customer closed his account, transferred his holdings to another broker-dealer, and then complained to a state regulator.
The complaint also alleges that Sullivan willfully failed to timely amend his Form U4 to disclose a material event that a reasonable employer, customer, or regulator would have viewed as relevant to his business and employment.
It is important to note that this is a complaint and not a final determination. Sullivan has not been found to have violated any rules at this stage.
Unauthorized trading is a serious allegation. FINRA rules require representatives to obtain customer authorization before executing trades in non-discretionary accounts. This requirement protects customers from having their assets used in ways they did not approve.
The failure to disclose material events on Form U4 is also a significant charge, as this form provides important information to firms and regulators about a representative's background.