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James Willing: FINRA Suspends Boston Broker Over Private Transactions

James Willing (CRD# 468560), a broker currently associated with Moors & Cabot, was recently sanctioned by the Financial Industry Regulatory Authority in connection to allegations he participated in undisclosed private securities transactions. Formerly a representative of Morgan Stanley in Boston, Massachusetts, Willing was issued a 35-day suspension and a fine of $7,500.

According to a Letter of Acceptance, Waiver and Consent (No. 2018057629501) dated January 2020, James Willing was associated with Morgan Stanley as a General Securities Representative from 2010 until February 2018, when the firm filed notice of his termination over concerns about “disclosures regarding involvement in private investments outside the firm.” FINRA’s findings go on to state that between June 2015 and December 2016 he participated in private securities transactions without providing prior written notice to, nor receiving written approval from Morgan Stanley. He allegedly invested $62,500 in a series of transactions “involving pooled investment fund interests offered by a limited partnership pursuant to Regulation D.” The findings state that he invested $12,500 on June 15, 2015, and another $50,000 in 2016. FINRA states further that these pooled investment fund interests “were securities,” and that he did not notify his firm in writing before participating in the transactions, even though Morgan Stanley’s policies forbade representatives from participating in private securities transactions without providing prior written notice and receiving approval. According to FINRA, he gave the firm written notification in February 2017, when he filed a private investment disclosure. FINRA found that these activities constituted violations of NASD Rule 3040 and FINRA Rules 3280 and 2010. As a result of the foregoing alleged conduct, he was issued a 35-day suspension and a fine of $7,500.

James Willing has been registered with Moors & Cabot in Boston, Massachusetts since 2019. His previous registrations include Morgan Stanley, UBS Financial Services, Wachovia Securities, Prudential Securities, Loeb Partners, Hornblower Weeks Noyes & Trask, Hornblower & Weeks Hemphill Noyes, and Hornblower Weeks Hemphill Noyes. He has passed four securities industry qualifying examinations and his BrokerCheck report lists nine state securities licenses. (Information current as of May 20, 2020.)

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