← Broker database 2025-03-31
Thurston Springer Financial Fined $150,000 for Multiple Supervisory Failures
According to FINRA, Thurston, Springer, Miller, Herd & Titak, Inc. dba Thurston Springer Financial has been censured and fined $150,000 for multiple supervisory failures including inadequate Reg BI procedures, Form CRS deficiencies, and failure to report customer complaints.
The firm's written supervisory procedures discussed Reg BI only in general terms and did not establish procedures for achieving compliance with Reg BI's Care and Conflict of Interest Obligations. The firm also failed to establish procedures for filing and delivering customer relationship summaries (Form CRS), including delivering Form CRS to prospective customers, updating it when necessary, and maintaining related records.
The firm's supervisory system for email reviews was inadequate and did not address reviews to identify potential customer complaints requiring reporting. The firm failed to timely amend Forms U4 to disclose that representatives were named as defendants in customer-initiated civil litigation involving sales practice violations, and failed to disclose the litigation to FINRA.
Additionally, the firm failed to establish procedures for reviewing outside brokerage accounts, failed to obtain duplicate statements for associated persons' accounts, failed to inspect its OSJ and branch locations, and failed to conduct reasonable supervisory control testing. The designated principal failed to provide required annual reports to senior management, and the CEO failed to make required certifications.
This case illustrates how interconnected supervisory failures can be. When a firm lacks proper procedures in one area, it often indicates broader compliance weaknesses. Investors should understand that these supervisory requirements exist to detect and prevent misconduct before it harms customers.