FINRA Fines Boston Firm $20K Over Private Placement Filing Lapses
By Staff

The Financial Industry Regulatory Authority has censured and fined Hoopoe Capital Markets, a Boston-based broker-dealer that sells private placements, $20,000 for failing to file required offering documents related to five private placement offerings.
According to FINRA, between July 2019 and January 2022, Hoopoe did not file a private placement memorandum or any other offering document connected to five private placement offerings sold by its registered representatives.
As a result, the firm violated FINRA Rule 5123, which requires any member to submit to FINRA a copy of any private placement memorandum, term sheet, or other offering document used in connection with such sales within 15 calendar days of the date of first sale – or to notify FINRA that no such offering documents were used.
A violation of Rule 5123 also constitutes a violation of FINRA Rule 2010, which mandates that members observe high standards of commercial honor and just and equitable principles of trade.
FINRA adopted Rule 5123 to enhance oversight and investor protection by requiring more timely and complete information about member firms’ private placement activities.
Hoopoe Capital agreed to a censure and $20,000 fine without admitting or denying FINRA’s findings.


