FINRA’s Department of Enforcement investigated Windle and alleged he solicited five individuals to invest approximately $40,000 in total an outside business between June 2013 and October 2013. The five individuals were college friends and not JP Morgan customers. According to FINRA, the outside business was a limited liability company formed to develop a mobile phone application and was created by Windle and two other JP Morgan registered representatives. During the relevant time period, JP Morgan’s policies and procedures prohibited firm employees from engaging in outside business activities without prior written notice and approval. Windle never disclosed these outside investments to JP Morgan according to FINRA.
Based upon the foregoing misconduct, FINRA alleges Windle violated NASD Conduct Rule 3040 and FINRA Rule 2010. Specifically, NASD Rule 3040 states no FINRA registered person may be an employee or receive compensation for outside business transactions unless he or she has provided prior written notice to their employer. Outside business transactions and selling away are prohibited activities because they serve to undercut the supervisory system implemented by FINRA-member firms and FINRA itself to protect the investing public.
Lufrano Law, LLC is a national securities litigation firm and has experience representing investors who have investment disputes with brokers and broker-dealers. If you lost money investing with Windle while JP Morgan employed him as a general securities representative, you may be able to recover your losses through FINRA arbitration. Our firm only receives a fee if you recover money. Please contact one of our attorneys at (800) 627-2179 to schedule a free consultation.