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The Financial Industry Regulatory Authority (FINRA) announced it has fined Deutsche Bank Securities Inc. $12.5 million for significant supervisory failures related to research and trading-related information it disseminated to its employees, called ‘hoots’ or ‘squawks,’ over internal speakers commonly known as ‘squawk boxes.’ Despite multiple red flags regarding the potential dissemination of confidential information, Deutsche Bank failed to establish adequate supervision over registered representatives’ access to hoots or their communications with customers regarding hoots. As part of the settlement, Deutsche Bank also agreed to provide a written certification that it has adopted and implemented supervisory systems and written procedures concerning hoots that are reasonably designed to achieve compliance with FINRA rules and federal securities laws.

FINRA found that Deutsche Bank was aware that hoots involving research and trading might contain confidential, price-sensitive information, and that there was a risk that material non-public information could be communicated over them. However, for several years, the firm repeatedly ignored red flags indicating that its supervision was inadequate, including internal audit findings and recommendations, multiple internal warnings from members of the firm’s compliance department, and internal risk assessments. Despite these red flags, the firm still failed to implement reasonable written policies, procedures and systems governing who should have access to the hoot information, how the employees should handle hoot information, and how supervisors should supervise employees to ensure compliance, and protection of confidential and material nonpublic information potentially communicated over the hoots.

Brad Bennett, FINRA’s Executive Vice President and Chief of Enforcement, said, “Recognizing and responding to red flags is the hallmark of proper supervision, particularly in areas involving confidential information. Deutsche Bank’s disregard of years of red flags including internal audit findings, risk assessments and compliance recommendations was particularly egregious given the risk that material nonpublic information could be communicated over squawk boxes.”

In settling this matter, Deutsche Bank neither admitted nor denied the charges, but consented to the entry of FINRA’s findings. As the mother of three children and a military spouse, Candice Pombar understands the financial struggles of military families, especially when she recalls how hard she and her husband fought to get out of debt early in their marriage.
Pombar is ready to launch a new fight to help other military families take charge of their personal finances as one of 50 select participants in the FINRA Investor Education Foundation (FINRA Foundation) 2016 Military Spouse Fellowship. This program provides military spouses with the training necessary to earn the AFC (Accredited Financial Counselor) designation.
“I discovered my heart for helping other people gain control over their finances after my husband and I worked very hard early in our marriage to get out of debt and live on a budget,” Pombar said. “I am excited to earn a professional designation as a financial counselor and put my passion to work.”

Starting in September, Pombar will begin the rigorous AFC coursework, combined with hands-on field experience through practicum work in military communities. This innovative program is tailored to meet and support the needs of military spouses through instructional webinars, self-scheduled exams and flexible practicum opportunities. The FINRA Foundation first launched the FINRA Foundation Military Spouse Fellowship program in 2006—and continues to administer it in partnership with the Association for Financial Counseling and Planning Education (AFCPE) and the National Military Family Association. The Fellowship covers the costs associated with completing the AFC training and testing. Since its inception in 2006, the program has awarded more than 1,400 Fellowships to military spouses across the United States and around the world.

“The FINRA Foundation Military Spouse Fellowship program is uniquely designed for the spouses of our servicemen and women who understand the rigors and culture of a military lifestyle,” said FINRA Foundation President Gerri Walsh. “Fellows can obtain not only marketable job skills, but also the resources and experiences they need to help countless military families build brighter financial futures.”

Recipients of the FINRA Foundation Military Spouse Fellowship commit to completing the courses of study and working in the financial counseling field serving their communities for up to two years. Since the program’s inception, Fellows working toward accreditation have collectively conducted in excess of 63,700 counseling sessions and classes reaching over 171,500 clients, logging more than 429,000 hours assisting service members and their communities.

Graduates often serve as financial counselors at family readiness and support centers, credit counseling and tax centers, financial aid offices and local military credit unions throughout the United States and abroad.
“The AFC certification ensures that FINRA Foundation Fellows have the education and experience needed to provide the highest level of financial care for military service members, families and veterans,” said Rebecca Wiggins, Executive Director of AFCPE. “The Fellowship program provides military spouses with a tailored framework through instructional webinars, self-scheduled exams, a strong professional network, and flexible practicum opportunities to optimize their potential for success.”

“Military spouses know first-hand the financial challenges troops and their families face,” said Joyce Raezer, Executive Director of the National Military Family Association (NMFA). “NMFA is proud to partner with FINRA and AFCPE to connect military spouses with the training that will not only lead to a productive career, but also allow them to help members of their community.”

The program is open to spouses of active-duty or retired Army, Navy, Air Force, Marine Corps, Coast Guard, and Army or Air National Guard or reserve component service members, as well as to spouses of U.S. Public Health Service Commissioned Corps and National Oceanic and Atmospheric Administration professionals..
“I hope to be an asset to the military community by helping our heroes be mission ready with their personal finances here at home,” Pombar added. “Money doesn’t buy happiness, but a balanced budget is a huge step in the right direction.”

The FINRA Investor Education Foundation provides investors with high-quality, easily accessible information and tools to better understand the markets and the basic principles of saving and investing. In 2006, the Foundation launched a multifaceted program to expand the saving and investing knowledge of military service members and their spouses, including a free, unbiased resource. A proud collaborator in the Department of Defense Financial Readiness Campaign, the Foundation also builds the capacity of military financial educators to support their communities and presents financial education forums at military installations worldwide.

AFCPE, the Association for Financial Counseling and Planning Education, is a nonprofit, professional organization dedicated to educating, training, and certifying financial counselors and educators. The Association’s vision is to be internationally recognized as the leading provider of professional development opportunities for financial educators, counselors, and researchers to improve the economic well-being of individuals and families worldwide.

The National Military Family Association is the leading nonprofit dedicated to serving the families who stand behind the uniform. Since 1969, NMFA has worked to strengthen and protect millions of families through its advocacy and programs. They provide spouse scholarships, camps for military kids, and retreats for families reconnecting after deployment and for the families of the wounded, ill, or injured. NMFA serves the families of the currently serving, retired, wounded or fallen members of the Army, Navy, Marine Corps, Air Force, Coast Guard, and Commissioned Corps of the USPHS and NOAA.

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Michael R. Anderson, JD


Ascent Law LLC
8833 S. Redwood Road, Suite C
West Jordan, Utah
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Telephone: (801) 676-5506