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Matt Rothchild Comment On Regulatory Notice 20-42

1) When I first joined my firm, I emphasized a BCP that answered the question, “What happens if we lose use of our primary office for an extended period of time?” With that in mind, I encouraged our office staff—particularly our IT function—to think in terms of carrying on a regular workday from an alternative location. IT spent several years gradually building up our remote working capability. When COVID came, our firm made a conscious decision to carry on as usual as long as possible and committed to closing the office only if a staff member was diagnosed with the infection.

2017054137002 Gary Wayne Hammond CRD 2660432 AWC jlg (2021-1613780402636).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2017054137002 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Gary Wayne Hammond (Respondent) Former General Securities Representative and Former General Securities Sales Supervisor CRD No. 2660432 Pursuant to FINRA Rule 9216, Respondent Gary Wayne Hammond submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020065035201 Christian Frank Lucchetto CRD 4648994 AWC va (2021-1613694002122).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2020065035201 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Christian Frank Lucchetto, (Respondent) General Securities Representative CRD No. 4648994 Pursuant to FINRA Rule 9216, Respondent Christian Frank Lucchetto submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020067455201 Javelin M. San Nicolas CRD 6722186 AWC sl (2021-1613694002709).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2020067455201 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Javelin M. San Nicolas (Respondent) Former General Securities Representative CRD No. 6722186 Pursuant to FINRA Rule 9216, Respondent Javelin M. San Nicolas submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.