Dalmore Group LLC has agreed to pay a fine of $375,000 as a part of a settlement with the Financial Industry Regulatory Authority (FINRA).
From January 2019 to December 2022, Dalmore failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with its suitability and best interest obligations in connection with its sale of private placements, in violation of Rule 15l-1(a)(1) under the Securities Exchange Act of 1934 (Regulation Best Interest or Reg BI), and FINRA Rules 3110 and 2010.
During the same period, Dalmore failed to establish and maintain a reasonable supervisory system to prevent misuse of material non-public information, in violation of FINRA Rules 3110 and 2010.
From January 2019 to the present, Dalmore has failed to fingerprint non-registered associated persons who are required to be fingerprinted, in violation of Section 17(f) of the Exchange Act, Exchange Act Rule 17f-2, and FINRA Rule 2010.
From October 2019 to the present, Dalmore has failed to report, or to timely report, the outside business activities of ten of its registered representatives on their Uniform Applications for Securities Industry Registration (Forms U4), in violation of Article V, Section 2(c) of FINRA’s By-Laws and FINRA Rules 1122 and 2010.
From October 2020 to the present, Dalmore has violated content standards in FINRA Rule 2210 through retail communications on three websites and in one web-based video series promoting the firm’s securities business.
From May 2022 to at least September 2023, Dalmore failed to specify a date by which a private offering’s minimum raise contingency had to be met, and released investor funds to the issuer before the contingency was met, in willful violation of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-9, and in violation of FINRA Rule 2010.
Finally, from August 2022 to January 2023, Dalmore provided late, incomplete, and inaccurate responses to FINRA requests for documents and information, in violation of FINRA Rules 8210 and 2010.
On top of the $375,000 fine, the firm has agreed to a censure.
