Greenbird Capital LLC has agreed to pay a fine of $ 50,000 as part of a settlement with the Financial Industry Regulatory Authority (Finra).
From May 2021 to December 2023, the company failed to establish, maintain and impose a system logically designed to achieve compliance with Finra’s telecommunications rules.
The company did not have a system or procedure to monitor the outgoing calls made by the company’s registered representatives for numbers in the DO-Not-Call national directory.
In addition, although one of the business gentleman has taken occasionally if the registered representatives called customers during the seasons allowed by Artra 3230, the company did not specify when or how often such revisions took place.
Following the relevant period hereof, the company implemented the use of a pre -existing form of relationship, revised its written supervision procedures to include the language facing general attraction and pre -existing form of relationships and stopped dealing with a cold call.
During this time, the company did not create or implement a system, including written procedures, logically designed to identify general private placement bids made in accordance with Article 506 (b) of regulation d.
The company’s written procedures did not prohibit registered representatives from participating in a general invitation of such bids or providing guidance on what was a pre -existing, meaningful relationship.
In addition, Greenbird Capital had no system for reasonably monitoring and documentation when the company had created a meaningful relationship with a future investor or to confirm- before being asked by a future investor for an offer- that the business had such a relationship with the investor.
In relation to the bids made during the period, the registered representatives made hundreds of thousands of calls to future investors without a reasonable system to ensure that the business established substantial relations with these people before attracting the individual for a particular investment.
As a result, with regard to some of the investors in at least one of the bids mentioned above, the company was unable to verify logically that there was a pre -existing, substantial relationship before the invitation.
From May 2021 to December 2023, Greenbird Capital sold investments in 14 private placements dependent on Article 506 (b) Safe Harbor, increasing about $ 24 million in capital.
The company agreed to a fine of $ 50,000 and accuracy.