At least when selling to individual investors, this case may serve as something of a warning that a firm is not able to avoid a due diligence obligation by labelling itself as a "finder," rather than as a placement agent.

FINRA's adding the Reg BI charge to the suitability charge is the wave of the future. It means that there is a violation of the federal securities laws, as well as a violation of FINRA Rules.

Governor Bowman's comments as to the scope of banking regulator authority have much in common with . They both warn against regulators who want to make the world a better place, whether as to social change or climate change, and rationalize the expansion of their regulatory authority to do so. But these are not tasks within the plain scope of the regulators' statutory missions, and in a world of limited resources, the economy would do better if the regulators concentrated their attention and…

For related commentary, see: .

It is noteworthy when a regulator does not impose a fine in connection with a disciplinary action .  Presumably  the violation was unintentional. That said, the violation was discovered by FINRA investigation, rather than self-discovery by the firm.  

In not imposing any fine, FINRA credited the firm for: