On May 16, 2022, FINRA published an Acceptance Waiver and Consent (“AWC”) in which FA, Robert Bennett Zamani, accepted a 14-month suspension and a $27,500 fine for violations of FINRA Rule 3270 (Outside Business Activities), Rule 2210 (Communications with the Public), Rule 4511 (Books and Records) and, as always, Rule 2010 (Standards of Commercial Honor). A copy of the AWC is available at: https://www.finra.org/sites/default/files/fda_documents/2020066847301%20Bennett%20Robert%20Zamani%20CRD%206198730%20AWC%20gg.pdf. The investigation of Zamani was triggered by a Form U5 filed by his former firm, Morgan Stanley.
The Rule 4511 violation was based on Zamani’s use of business-related text messages that were not retained by Morgan Stanley, effectively causing Morgan Stanley to violate its obligation to maintain such communications under Rule 4511. This is an easily avoidable rule violation that so many FAs seem to fall into.