Jefferies LLC agreed to resolve a disciplinary action brought by the Financial Industry Regulatory Authority for violations of requirements to hold customer fully-paid and excess margin securities in good control locations from July 2013 through March 2016. FINRA charged that during this time period, on occasion, Jefferies held certain customer securities in non-US clearance accounts that were subject to liens by the foreign depository; failed to promptly transfer certain shares of a few customers from 14 foreign clearance accounts that were not good control locations to appropriate segregation accounts; and did not have written supervisory procedures reasonably designed to comply with the SEC’s customer protection rule for customer securities held at foreign depositories (click here to access SEC Rule 15c3-3). Earlier this month, a different broker‑dealer agreed to pay a fine of US $2.8 million to FINRA to also settle charges for not, on occasion, segregating customers’ fully-paid-for foreign and domestic securities in good control locations as required by law. (Click here for background in the article, “FINRA Fines One Broker-Dealer US $2 Million for Flawed Email Review System, and Another Broker-Dealer US $2.8 Million for Inadequate Segregation of Customer Securities” in the Bridging the Week edition of January 7, 2018.)