Citigroup Global Markets Inc. was fined US $15 million by the Financial Industry Regulatory Authority, principally for supervisory failures relating to its handling of equity research between January 2005 and 2013. According to FINRA, during this time, CGMI equity research analysts engaged in “inappropriate communications” both with external clients as well as internal sales and trading personnel, “including providing non-public research information …before the research was published.” This conduct, claimed FINRA—which was alleged to be a violation of applicable federal securities laws and FIRNA rules—was encouraged by CGMI’s compensation arrangements that rewarded equity research analysts based on feedback from clients and sales personnel. For example, between October 2010 and 2013, equity research analysts occasionally participated in “idea dinners” where they expressed views on stocks inconsistent with their or other CGMI-published research reports. Moreover, when CGMI detected violations of its rules regarding selective dissemination, “it failed to effectively discipline its equity research analysts and therefore failed to adequately enforce its policies and deter future violations,” said FINRA. In addition, claimed FINRA, on two occasions in July 2011, an equity research analyst participated in investment banking roadshows contrary to FINRA requirements. In addition to payment of a fine, CGMI agreed to submit a plan to FINRA within 60 days evaluating its research policies and procedures. CGMI did not admit or deny any of FINRA’s findings. In 2012 and 2013, CGMI agreed to pay two fines totaling US $32 million to the Commonwealth of Massachusetts related to the handling of non-public research information.