Alejandro Falla Barred From Association with FINRA Members
On February 9, 2017, Alejandro Falla (CRD #5064828, Miami, Florida) submitted an AWC in which he was barred from association with any FINRA member in any capacity.
Without admitting or denying the findings, Falla consented to the sanction and to the entry of findings that he failed to disclose the use of non-market foreign exchange (FX) rates in connection with a series of bond swap transactions in retail customer accounts. The findings stated that Falla’s member firm, operating through Alejandro Falla, executed numerous retail customer transactions with inaccurate valuations when converted into U.S. dollars, which affected multiple customer accounts. Falla either manually or caused firm personnel to input non-market FX rates for bond swap transactions in his customer accounts.
The findings also stated that the firm’s confirmations and account statements did not disclose to customers the use of a non-market FX rate or the excessive nature of the markups in connection with the bond swap transactions. Alejandro Falla did not disclose that he used non-market FX rates away from the spot rate to value retail customer bond transactions, and did not disclose to retail customers its impact on the valuation of the bond swap transactions. The findings also included that Falla entered or caused the entry of non-market FX rates into the firm’s trade execution system in connection with bond swap transactions involving foreign currency denominated bonds in retail customer accounts, thereby causing the firm to maintain inaccurate books and records. FINRA found that the firm, acting through Alejandro Falla, failed to establish and maintain a supervisory system and further failed to establish, maintain, and enforce WSPs for the firm that were reasonably designed to identify and prevent the use of non-market FX rates, excessive markups, short-term trading, undue concentration and unsuitable use of margin in customer accounts.
For further information about this securities law blog post, please contact Brenda Hamilton, Securities Attorney at 101 Plaza Real S, Suite 202 N, Boca Raton, Florida, (561) 416-8956 or by email at [email protected]. This securities law blog post is provided as a general informational service to clients and friends of Hamilton & Associates Law Group and should not be construed as, and does not constitute, legal and compliance advice on any specific matter, nor does this message create an attorney-client relationship. Please note that the prior results discussed herein do not guarantee similar outcomes.
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