An enforcement action by the Financial Industry Regulatory Authority against a Manhattan broker-dealer shows why a firm should confirm that its investment bankers effectively communicate the terms of their deals with the firm's financial and operations principal, or FinOp. Without admitting or denying FINRA's findings that it violated Rule 15c3-1 under the Securities Exchange Act of 1934 and FINRA Rule 2010, the firm, BTG Pactual US Capital, LLC, a subsidiary of the Brazilian investment bank Banco BTG Pactual SA, consented to being censured and fined $20,000. FINRA found that on five days between September 2010 and January 2011, when acting as an initial purchaser in an offering of corporate debt as part of a syndicate of underwriters in which it had a firm commitment to buy securities, BTG Pactual conducted a securities business while net capital deficient. On each such day BTG's FinOp did not apply the "haircut" required by 15c3-1(c)(2)(viii) when computing net capital based
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