According to FINRA, Thomas Alvin Vernor III was assessed a deferred fine of $5,000 and suspended from association with any FINRA member in all capacities for five months for willfully failing to amend his Form U4 to disclose a felony charge.

Vernor knew he was required to disclose the felony charge on his Form U4 but voluntarily chose never to disclose it. This was not an oversight or mistake—Vernor made a conscious decision not to disclose the criminal charge despite knowing his disclosure obligation. The term "willfully" indicates that Vernor acted with knowledge that his conduct was wrongful.

Form U4 is the uniform registration form that must be kept current with accurate information about criminal charges, customer complaints, regulatory actions, and other disclosure events. This information is essential for firms to evaluate whether individuals remain eligible for registration and for investors to access accurate background information through FINRA's BrokerCheck system.

By never disclosing the felony charge, Vernor prevented both his firm and investors from having access to material information about his background. Felony charges are among the most serious disclosure events because they raise fundamental questions about an individual's character and fitness to handle investor funds and provide financial advice.

The five-month suspension reflects the seriousness of willfully failing to disclose a felony charge. The willful nature of the violation—knowing about the disclosure requirement but choosing not to comply—is particularly concerning because it demonstrates a deliberate decision to conceal material information from regulators, the firm, and investors.

For investors, this case underscores the critical importance of checking FINRA's BrokerCheck before working with financial professionals. BrokerCheck relies on accurate Form U4 information, but as this case demonstrates, not all registered persons comply with disclosure requirements. Investors should be particularly cautious about representatives who have disclosure violations, as these violations indicate a willingness to conceal important information. The suspension is in effect from June 20, 2023, through November 19, 2023.