FINRA Fines Broker-Dealer $250K for Customer Protection Rule Violations

Broker-dealer Vision Financial Markets has been censured and fined $250,000 by the Financial Industry Regulatory Authority for repeatedly failing to accurately calculate its required customer and proprietary accounts of broker-dealers, or PAB, reserve requirements, resulting in underfunded reserve accounts and significant compliance failures.

According to FINRA, at various times between April 2020 and November 2022, Vision’s inaccurate computations of its required reserves led to hindsight deficiencies in its reserve accounts. These deficiencies, which are shortfalls discovered after the fact, ranged from approximately $499,000 to $7.7 million in the customer reserve account, and included spikes of $32 million on Dec. 31, 2020, and $15.8 million on Sept. 30, 2021. The firm also had PAB reserve deficiencies of $2.5 million and $4.1 million in May and July 2022, respectively.

These failures violated key regulations, including the Customer Protection Rule – Securities Exchange Act of 1934 Rule 15c3-3 – which is designed to safeguard customer assets and ensure their prompt return in the event of a firm’s insolvency.

Between April 2020 and November 2022, Vision improperly included certain debit balances in its reserve formula by:

• Improperly using net position information from foreign omnibus introducing broker customers for its calculations;
• Incorrectly netting credit balances against debit balances for the same customer in concentrated margin debit computations;
• Treating partners in a general partnership as separate customers instead of a single customer in concentrated margin debit computations; and
• Improperly excluding a foreign consolidated margin account from concentrated margin debit computations.

Also, from May to July 2022, Vision miscoded six U.S. and foreign broker-dealer proprietary trading accounts as non-customer accounts instead of PABs in its back-office system. This error excluded the accounts’ credit and debit balances from the PAB reserve computations, causing the underfunding.

The firm’s failure to properly calculate its reserve obligations meant it also maintained inaccurate books and records and filed inaccurate reports with regulators.

A central part of FINRA’s findings involved Vision’s supervisory failures over a five-year period, from April 2020 to April 2025.

FINRA found that Vision failed to establish and maintain a supervisory system, including written supervisory procedures reasonably designed to ensure compliance with the reserve obligations. The WSPs did not address such topics as the requirement to calculate customer reserves based on settled positions at the close of the last business day of the week or how to perform accurate concentrated margin debit computations, among other deficiencies.

Vision, which has been a FINRA member since 2008, did not admit or deny the findings but consented to the censure and fine. The firm provided information in April 2025 indicating it has since updated its supervisory system and WSPs to address the deficiencies.

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