The following information appeared on FINRA’s website under “Disciplinary and Other FINRA Actions, May, 2013.”

vFinance Investments, Inc. (CRD #44962, Boca Raton, Florida)

consented to the described sanctions and to the entry of findings that it acted as the private placement agent for a placement of up to $5 million in convertible notes a company issued. Investors, some of whom were the firm’s customers, invested a total of $5,950,000 in the private placement while the issuer was on the firm’s restricted list for the duration of its participation in the offering.

FINRA’s findings stated that the firm did not adequately supervise the purchases of stocks on the restricted list even though the firm’s procedures required it to monitor purchases of securities of issuers on its restricted list, including those for which it was conducting offerings.

The firm failed to adequately enforce the procedures and instead authorized customer purchases of the stock without
conducting an adequate inquiry into the facts and circumstances surrounding those purchases, thereby failing to reasonably supervise activity in the issuer’s stock in a manner reasonably designed to achieve compliance with Regulation M. The findings also stated that the firm failed to disclose involvement of a statutorily disqualified person who worked closely with firm employees in connection with the private placement, communicating directly with the firm’s investment banking department and others.

FINRA’s findings also included that a registered representative involved in the solicitation of purchases of the stock used his personal email account to solicit purchases of stock and for other business purposes, and forwarded and addressed some of the emails to firm email addresses of other firm employees, including managerial-level employees. The firm should have been on heightened awareness of its obligations to supervise the use of external email accounts.

FINRA found that the firm did not create and implement procedures reasonably designed to review incoming and outgoing
securities-related and investment banking-related correspondence, including electronic correspondence, so it did not adequately supervise employees’ outside email accounts.
(FINRA Case #200901616000)

The following information was obtained on FINRA’s BrokerCheck:

Main Office Location:
1200 N. FEDERAL HIGHWAY
SUITE 400
BOCA RATON, FL 33432
Regulated by FINRA Florida Office

Mailing Address:
1001 FOURTH AVENUE
SUITE 3750
SEATTLE, WA 98154

This ends the information from FINRA’s website.

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