FINRA

YARBROUGH FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

LETTER

Suspension

ANY CAPACITY

N/A

8/22/2012

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS, AND FINRA RULE 9554, YARBROUGH IS SUSPENDED AUGUST 22, 2012 FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

FINRA

FINRA RULES 2010, 8210, NASD RULE 2370: YARBROUGH BORROWED $45,000 FROM A CUSTOMER; YARBROUGH HAD NOT REQUESTED OR RECEIVED PERMISSION FROM HIS MEMBER FIRM TO BORROW MONEY FROM THE CUSTOMER. THE CUSTOMER LATER DIED. YARBROUGH RESPONDED IN WRITING TO A REQUEST FOR INFORMATION FROM FINRA; IN THE WRITTEN RESPONSE, YARBROUGH ADMITTED THAT, AT THE TIME HE BORROWED MONEY FROM THE CUSTOMER, HE KNEW THAT BORROWING FROM A CUSTOMER VIOLATED BOTH INDUSTRY RULES AND HIS MEMBER FIRM'S POLICY. YARBROUGH ALSO ADMITTED THAT, AT THE TIME HE BORROWED MONEY FROM THE CUSTOMER, HE INSTRUCTED AN INDIVIDUAL WHO HELD POWER OF ATTORNEY FOR THE CUSTOMER NOT TO REVEAL THE LOAN TO HIS FIRM. YARBROUGH REPAID THE CUSTOMER'S ESTATE $5,000 OF THE $45,000. YARBROUGH FAILED TO APPEAR FOR A FINRA ON-THE-RECORD INTERVIEW.

Decision

Bar (Permanent)

All Capacities

Indefinite

2/17/2012

DEFAULT DECISION RENDERED JANUARY 20, 2012 WHEREIN YARBROUGH IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. THE HEARING OFFICER DID NOT ORDER RESTITUTION BECAUSE FINRA ENFORCEMENT REPRESENTS THAT THE CUSTOMER HAS BEEN MADE WHOLE. DECISION IS FINAL FEBRUARY 17, 2012.