Howard Hull Fined & Suspended for Firm's Supervisory Failures

FINRA suspended California broker and principal Howard Lawrence Hull, fining him $20,000 for a series of supervisory failures at his firm, HLH Securities, Inc., of Newport Coast, CA, including failures in implementing supervisory policies, and failing to review and retain business-related e-mails.

AWC #2014038992501

The findings indicate that as HLH Securities' sole principal, owner, and Chief Compliance Officer, Hull (CRD #2698088) failed to establish an adequate supervisory system, including a failure to update the firm's written supervisory procedures (WSPs) to comply with FINRA rules.

Investigators also found that Hull failed to retain and supervise certain business-related e-mails, and failed to establish a system in order to retain business-related e-mails.

According to the AWC, Hull and HLH Securities lacked a reasonably designed supervisory system and failed to require its representatives to provide Hull with documentation for private securities transactions so that he could record and supervise the activity.

The investigation notes that as a result of this failure, at least 21 private securities transactions at HLH Securities went unsupervised, unrecorded, or were inadequately supervised.

FINRA also stated that Hull failed to establish procedures to review outside business activities and failed to conduct corresponding reviews of these activities, even when representatives provided written disclosures that described the outside business activities they were engaged in.

Finally, investigators found that even though HLH's procedures prohibited firm associates from using e-mail for business-related communications, Hull and at least 10 additional representatives used personal e-mail accounts to conduct firm business.

The findings state that Hull failed to review and retain these e-mails, and furthermore failed to establish procedures related to the review and retention of business-related e-mails.

If you have invested with HLH Securities, owner Howard Lawrence Hull, or with any broker, financial adviser, or firm whose supervisory failures, including inadequate private securities transaction or outside business activity review systems and failure to retain and review business-related e-mails, have proven harmful to your investments or interests due to these violations of FINRA rules, please call The Law Offices of Jonathan W. Evans & Associates at (800) 699-1881 for an investigation and consultation.

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