Merrill Lynch, Pierce, Fenner & Smith, Incorporated, agreed to pay a fine of US $1.25 million to the Financial Industry Regulatory Authority to resolve charges that it failed to fingerprint or properly screen 4,500 of persons associated with it (“associated persons”) from January 1, 2009 through October 28, 2013. According to FINRA, this oversight was attributable, in part, to Merrill’s acquisition by Bank of America Corporation on January 1, 2009. FINRA members are obligated to screen potential associated persons for potential statutory disqualifications under FINRA’s by-laws and rules (click here to access FINRA By-laws Article III, Section 3(b)) and to fingerprint potential associated persons under applicable federal law and SEC rule (click here to access SEC Rule 17f-2). Merrill was also charged with failing to have established and maintained an adequate supervisory system and not to have implemented and enforced written supervisory procedures reasonably designed to achieve compliance with the relevant securities laws and regulations.