Ziv Investment Company, a broker-dealer headquartered in Chicago, Illinois, and Peter Gordon Ziv, president, chief compliance officer and principal of Ziv Investment Company, were fined $75,000.00 and $10,000.00, respectively, for failing to supervise, inter alia, transactions and discretionary trading by stockbrokers at Ziv Investment Company’s branch office. Letter of Acceptance, Waiver and Consent, No. 2014039231701 (Sept. 26, 2017).
According to the AWC, between July 16, 2012, and October 19, 2014, Ziv, on behalf of his firm, neglected to create and implement written supervisory procedures concerning investment orders and business transactions. Apparently, the firm’s written supervisory procedures had conflicting meanings, and there was no consensus in the firm as to which supervisors were responsible to review and record transactions. Apparently, unqualified staff members approved of twenty-eight options transactions effected in customer accounts.
The AWC additionally stated that twenty-three discretionary trading customer accounts were established with Ziv Investment Company from July 16, 2012 to October 19, 2014, where the firm failed to evidence a supervisory review and approval of the customer’s investment accounts. As a result, there was no proof that the firm or Ziv determined the customers’ accounts to be approved for discretionary trading. Consequently, FINRA alleged that the firm and Ziv committed supervisory failures related to discretionary trading accounts; conduct violative of NASD Rule 2510.
Financial Industry Regulatory Authority (FINRA) Public Disclosure reveals that Ziv has been fined $10,000.00 and suspended from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity, and his firm was censured and fined $30,000.00, based upon consenting to findings that he effected unauthorized short sale transactions with customer funds, and failed to supervise the firm’s activities. Letter of Acceptance, Waiver and Consent, No. 20120323214 (Sept. 2013).
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