Alexander Investment Services Co has agreed to pay a fine of $25,000 as a part of a settlement with the Financial Industry Regulatory Authority (FINRA).

Since June 30, 2020, Alexander Investment Services has recommended securities to retail customers. However, from June 30, 2020, until the present, Alexander Investment Services has failed to establish and maintain written policies and procedures reasonably designed to achieve compliance with Securities Exchange Act of 1934 Rule 15/-1 (Regulation Best Interest or Reg BI).

The firm’s written policies and procedures referred to an associated person’s obligation to act in a customer’s best interest, but contained no provisions specifically relating to the obligations set forth in Reg BI.

On March 11, 2024, the firm updated its policies and procedures, which remain in effect, but they discuss Reg BI only in general terms, without addressing conflicts of interest or Reg BI’s specific requirements for acting in the best interest of retail customers.

Additionally, the firm’s written supervisory procedures do not designate the principal responsible for Reg BI compliance or detail the supervisory steps and reviews that should be undertaken by that principal-including the frequency of those reviews or how such reviews should be conducted or evidenced.

By failing to comply with the Compliance Obligation and the Conflict of lnterest Obligation, Alexander Investment Services violated Exchange Act Rule 15/-1 (a)(l) and FINRA Rules 3110 and 2010.

The firm has agreed to the following sanctions:

• a censure;
• a $25,000 fine; and
• an undertaking that a member of the firm’s senior management who is a registered principal of the firm will certify in writing that the firm has remediated the issues and implemented a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with Regulation Best Interest.