FINRA

Without admitting or denying the findings, Heely consented to the sanctions and to the entry of findings that he engaged in an undisclosed outside business activity for which he received compensation. The findings stated that without providing prior written notice to his member firm, Heely registered and incorporated a company. The company, through Heely, then entered into a contract with another business to raise money through a private placement offering of senior secured notes. Heely solicited potential investors, none of whom were firm clients, to invest in the offering. Although Heely's outside business activities did not result in any investments, Heely received $17,000 as compensation for his work. Heely actively concealed his involvement with the company and the offering by conducting those activities through a personal email address and by falsely denying engaging in any outside business activities in communications with his firm.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$5,000.00

Suspension

All capacities

Two months

5/4/2020

7/3/2020