FINRA Private Placement and Variable Annuity Fraud and Breach of Fiduciary Duty Attorney, Russell L. Forkey, Esq.
Noble International Investments, Inc. (CRD #15768, Boca Raton, Florida) submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $27,500. Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings that it executed short sale transactions and failed to report each of the transactions to the OTCRF with a short sale modifier. The findings stated that the firm failed to provide written notification disclosing to its customer that transactions were executed at an average price and, for one of these occasions, also failed to disclose that it was a market maker in each such security. The findings also stated that the firm failed to show the correct entry time on brokerage order memoranda and failed to show the correct execution price on the memorandum for one of these brokerage orders. The findings also included that the firm failed to preserve, for a period of not less than three years, the first two in an accessible place, one customer confirmation and a copy of the firm’s SEC Rule 606 reports made publicly available for several calendar quarters. (FINRA Case #2008014711601).