FINRA additionally acknowledged that a few of Haywood USA’s Canadian actions had been in violation of FINRA guidelines as within the providing of 236 Canadian non-public placements Haywood USA did not file providing paperwork with FINRA.
In accordance with the settlement order, Haywood USA has provided American customers a sort of Canadian non-public placement providing known as “non-brokered non-public placements” (NBPPs), whereby a agency is just not the agent of the issuer, however acts as a “finder” introducing buyers to the issuer. The order states that Haywood USA typically didn’t conduct due diligence of NBPPs past “a search and assessment of the issuer’s latest public filings.”
“To the extent the agency obtained any info from the issuer, Haywood USA typically sought minimal info and relied totally on the issuer with little to no unbiased verification,” the order reads. “Typically, the agency didn’t conduct any unbiased investigation, reminiscent of inquiring about previous or pending litigation or disciplinary issues, reviewing the issuer’s key contracts, exploring the issuer’s marketing strategy, or conducting a web site go to.”
As a part of the settlement, Haywood USA has been served a censure, a $175,000 (USD) high quality, and an endeavor {that a} senior member of the agency will certify that they’ve carried out an applicable supervisory system to take care of compliance with FINRA guidelines.
