Dustin Cain Walsh, of Saint Louis, Missouri, a stockbroker with Scottrade, Inc., was fined $5,000.00 and suspended from associating with any Financial Industry Regulatory Authority (FINRA) member firm in any capacity after consenting to findings that he obstructed a FINRA investigation into allegations of Walsh’s unauthorized outside business activities. Letter of Acceptance, Waiver and Consent, No. 2015046660801 (July 18, 2016).
According to the AWC, Walsh engaged in outside business activities as a real estate agent for a realty company, REP. Although Walsh apparently disclosed his participation in this regard to his firm, he was informed by Scotttrade that he needed to cease his conduct due to possible conflicts of interest. As such, Scotttrade told Walsh that he was not approved to engage in the activities and to stop associating with REP by a certain deadline.
The AWC stated that Walsh eventually informed FINRA, via Form U4, that his outside business activities as a real estate agent had ceased. However, Walsh had not actually ceased from such outside business activities, according to the AWC. The AWC stated that on June 26, 2015, which was after the deadline set by Scotttrade for Walsh to end his association with REP, Walsh was still doing business with REP and was listed on REP’s website. FINRA found that Walsh, from June 2014 through June 2015, was compensated $20,000.00 for his real estate transactions that were not approved through Scotttrade.
The AWC subsequently stated that on July 1, 2015, Scotttrade again informed Walsh about his unauthorized conduct and demanded that he stop participating. Apparently, just days later, Walsh continued to remain involved with REP and was still listed on the firm’s site.
Scotttrade reportedly instructed Walsh a final time on July 14, 2015. However, on July 29, 2015, Walsh facilitated a property sale and closing with REP. The following day, Scotttrade terminated Walsh. FINRA ultimately found that Walsh’s continued engagement in unauthorized outside business activities was violative of FINRA Rules 2010 and 3270.
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