In June 2014, FINRA announced that Dawson James Securities, Inc. submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured, fined $75,000, and required to revise its Written Supervisory Procedures.

Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that the firm’s Written Supervisory Procedures failed to provide for one or more of the four minimum requirements for adequate Written Supervisory Procedures in several subject areas, including registered representatives’ disclosure of potential conflicts of interests to clients; registered representatives’ trading in the opposite direction of solicited customer transactions; sales practice concerns, including unauthorized trading, suitability, excessive trading and free-riding; concentrations of securities in clients’ accounts; sharing of profits or losses in clients’ accounts; wash sales; coordinated trading; marking the open and marking the close; cancel-rebill transactions in clients’ accounts; and the review of registered representatives’ electronic communications.

The findings also stated that the firm failed to investigate numerous red flags relating to a registered representative’s activities. The firm failed to enforce its Written Supervisory Procedures, which specified that all electronic correspondence, whether incoming or outgoing, would be reviewed on a daily basis. The firm failed to ensure that its head trader was reasonably carrying out his delegated supervisory responsibilities relating to proprietary trading, trade reporting, clock synchronization, short sale compliance, compliance with the Manning Rule, mark ups and mark downs, and compliance with inventory guidelines.