Stephen James Sullivan (CRD #3123249, Massapequa Park, New York)

Stephen James Sullivan (CRD #3123249, Massapequa Park, New York)

September 17, 2024 – An OHO decision became final in which Sullivan was barred from association with any FINRA member in any capacity. The sanction was based on findings that Sullivan failed to provide on-the-record testimony, information, and documents requested by FINRA pursuant to FINRA Rule 8210 in connection with an investigation into potential churning and excessive trading in his customers’ accounts. The findings stated that initially Sullivan appeared with counsel at testimony and testified for almost five hours. During his testimony, FINRA asked Sullivan whether he changed the investment strategy he recommended to his customers following the implementation of Reg BI. Sullivan refused to answer the question and stated that he would not provide additional testimony. At the time that Sullivan terminated the on-the-record testimony, FINRA still had a substantial number of questions remaining, including questions about Sullivan’s trading in other customers’ accounts. Ultimately, Sullivan refused to provide any additional testimony and also failed to provide documents and information requested by FINRA pursuant to FINRA Rule 8210. The additional testimony, documents, and information FINRA sought were material to its investigation into Sullivan’s potential churning and excessive trading in customer accounts at his member firm. (FINRA Case #2018056490311)