Stirlingshire Investments Sanctioned, Fined over ETF Sales

New York City-based broker-dealer firm Stirlingshire Investments (CRD# 310576) was recently censured and fined in connection with allegations relating to the recommendation of inverse or leveraged exchange-traded funds, also known as NT-ETFs. According to a Letter of Acceptance, Waiver, and Consent (No. 2023077093401) issued in January 2026, the firm allegedly failed “to establish, maintain, and enforce a reasonable supervisory system, including written supervisory procedures” concerning the recommendations of these products. It also allegedly failed to file proper materials with FINRA for two private placements offerings.

As the AWC Letter states, three representatives of Stirlingshire Investments allegedly recommended NT-ETFs to “more than 25 retail customers” between November 2022 and April 2024. The representatives did this even though the firm allegedly “failed to establish, maintain, and enforce written policies or procedures reasonably designed to achieve compliance with Reg BI’s Care Obligation with respect to its recommendations of NT-ETFs, and to supervise such recommendations.” In fact, the firm’s written supervisory procedures forbade representatives from purchasing NT-ETFs in customers accounts, specifically directing firm supervisors to cancel such purposes; in spite of this, the firm “did not enforce that prohibition” or establish alerts or other tools to detect and evaluate potential NT-ETF recommendations. As the Letter notes, NT-ETFs are risky and complex investments that are generally not suitable for retail investors who intend to hold them for more than a single trading session.

The Letter goes on to describe allegations that Stirlingshire Investments sold “two private placement offerings of unregistered securities issued by [its] parent company” to a total of 21 investors without providing these investors copies of the relevant private placement memorandums, and without filing offering materials with FINRA. Finding that all of the above-described alleged conduct violated FINRA rules, FINRA censured the firm and ordered it to pay a fine of $40,000.

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