In January 2014, FINRA announced that Jonathan Samuel Perry, employed by MML Investors Services, LLC, submitted a Letter of Acceptance, Waiver and Consent in which he was fined $5,000 and suspended from association with any FINRA member in any capacity for five business days.
Without admitting or denying the findings, Perry consented to the described sanctions and to the entry of findings that while registered with his member firm and in anticipation of his move to a new firm, he moved documents related to firm customers he serviced from his firm office to his home. The findings stated that the documents contained non-public personal information, as that term is defined under Regulation S-P of the Securities Exchange Act of 1934, and Perry moved them without authorization and in contravention of his firm’s policies. Among other things, the non-public personal information included customers’ asset and income information, health information, addresses, birthdates and employment information. By removing the customers’ files from his firm’s control and possession, Perry placed the customers’ non-public personal information at risk.