The AWC charged Hemingway with violating NASD Conduct Rules 3030 and FINRA Rule 2010 (and its predecessor NASD Rule 2110).

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Further, by producing and then distributing these summaries to his customers, Iola was deemed to have violated NASD Conduct Rules 2110 (for conduct before December 15, 2008), 2210(d)(1)(A) and 2210(d)(1)(B), and FINRA Rule 2010 (for conduct after December 14, 2008).

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Ultimately, the AWC alleged that Hesse had failed to reasonably supervise President Esposito and also failed to reasonably review the trades and wire transmissions directed by the Client for potentially suspicious activity and other irregularities, in violation of NASD Conduct Rules 3010 and 2110 and FINRA Rule 2010.

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