It is somewhat unusual for an enforcement action to be taken against the FinOP rather than the firm.  

Firms should give consideration as to how this expansion of operating hours will impact operations, accounting, and contractual terms. At what hour of the day do their books "close" for the day? What time of day is a Fedwire payment required to be received?  

This is yet another example of an absence of any relationship between the seriousness of the misconduct of an individual broker and the severity of a penalty. See  for a recent case in which an individual broker, who charged less than $5,000 of personal credit card expenses to his employer, was fined $5,000 and received a six month suspension. The individual in the instant case removed and transferred information that was almost certainly worth more than $5,000 and violated customer…

As previously noted, the fines and other penalties that FINRA imposes on individual representatives seem completely disconnected from the actual harm done.  

In this case, a representative is fined $5,000 and is subject to a six-month suspension for essentially stealing less than $5,000 from his employer, which is (not to excuse the crime) a big institution. A broker was  $2,500 and subject to a four-month suspension for failing to report an outside business activity,…