According to FINRA, United First Partners LLC and Elizabeth Anne Dickerson have been sanctioned for multiple supervisory failures, including inadequate oversight of outside brokerage accounts and research department information barriers.

The firm was censured and fined $215,000, while Dickerson was fined $5,000 and suspended from association with any FINRA member in any principal capacity for one month. The violations revealed systemic failures in the firm's supervisory framework.

The investigation found that the firm's procedures failed to identify steps to verify receipt and review of duplicate statements for outside brokerage accounts. Dickerson relied on a manual process to request statements but did not track which statements she requested or verify their receipt. For approximately a year during the COVID-19 pandemic, Dickerson failed to review any outside brokerage account statements while working remotely, despite knowing statements were being sent to the firm's office.

Critically, the firm and Dickerson failed to establish policies restricting information flow between research department personnel and sales and trading staff. There were no physical or information barriers, and research analysts regularly circulated pre-publication draft reports to sales and trading staff for input, including on recommendations. This practice creates serious concerns about potential front-running and conflicts of interest.

The firm also failed to report TRACE-eligible transactions, municipal transactions to RTRS, and provide customers with accurate options confirmations. These reporting failures undermine market transparency and regulatory oversight.

For investors, this case highlights the importance of information barriers within brokerage firms. When research and trading departments can freely share information, it creates opportunities for abuse that can disadvantage retail investors who don't have access to the same advance information.