Vivek Tangudu Banned by FINRA for Lack of Cooperation

Background

On August 19, 2021, Tangudu worked at Merrill Lynch without being registered. Merrill submitted an amended Form NRF on May 16, 2023, stating that Tangudu’s association ended on May 15, 2023. Tangudu is not registered with or associated with any FINRA member firm. However, he is still subject to their guidelines under Article V, Section 4 of FINRA’s By-Laws.

Allegations on Vivek Tangudu

Tangudu violated FINRA Rules 8210 and 2010 by refusing to appear for on-the-record
testimony requested by them pursuant to Rule 8210.

Overview

On October 4, 2023, an AWC (Acceptance, Waiver, and Consent) was issued, resulting in Tangudu being prohibited from associating with any FINRA member in any capacity. Without acknowledging or denying the findings, Tangudu agreed to the penalty and the acceptance of the findings. The sanction was imposed because Tangudu declined to participate in on-the-record testimony requested by them during its investigation into the circumstances surrounding his member firm’s Rule 4530 filing. The filing indicated that Tangudu was terminated by the firm due to his lack of cooperation during an internal investigation.

Further Details

Merrill filed a FINRA Rule 4530 statement saying they ended the employment of the respondent because he didn’t cooperate during an investigation. Rule 8210 lets them request information from people related to their investigations and ask them to testify under oath.

Not following those requests breaks Rules 8210 and 2010.

On September 11, 2023, FINRA asked the respondent to give official testimony related to Merrill’s Rule 4530 statement. The respondent will not appear for the requested testimony.

Being barred from working with any member in any role. Respondent understands that being barred will result in a statutory disqualification, which means he cannot work in any capacity, even clerical or ministerial, with any member for the duration of the bar. On a date that FINRA sets, the sanctions in this AWC will begin. A bar or expulsion will start when this AWC is approved or accepted.

Key Points

1. On May 15, 2023, Vivek’s association with Merrill Lynch ended, and an amended Form NRF was submitted on May 16, 2023.
2. Tangudu, though not currently associated with any member firm, is still subject to their guidelines per Article V, Section 4 of FINRA’s By-Laws.
3. Allegations against Tangudu include violations of Rules 8210 and 2010 for refusing to appear for on-the-record testimony regarding a Rule 4530 filing by Merrill.
4. An AWC issued on October 4, 2023, resulted in Tangudu being barred from associating with any member in any capacity. He accepted the penalty without admitting or denying the findings.
5. Merrill Lynch filed a Rule 4530 statement citing Tangudu’s lack of cooperation during an internal investigation as the reason for his termination, leading to the FINRA investigation and subsequent sanctions.

Conclusion

In conclusion, Vivek Tangudu‘s association with Merrill Lynch ended on May 15, 2023, as reflected in an amended Form NRF submitted on May 16, 2023. Tangudu is still subject to FINRA’s rules under Article V, Section 4 of its By-Laws despite not currently being associated with any member firms. Allegations arose regarding his violation of FINRA Rules 8210 and 2010 for refusing on-the-record testimony related to Merrill’s Rule 4530 filing.

The ensuing Acceptance, Waiver, and Consent (AWC) issued on October 4, 2023, resulted in Tangudu accepting a prohibition from associating with any member in any capacity. Due to his refusal to take part in testimony that FINRA had requested during an investigation into the circumstances surrounding his termination from Merrill Lynch, he received this punishment. Merrill’s Rule 4530 statement cited Tangudu’s lack of cooperation during an internal investigation as the basis for his termination, prompting regulatory scrutiny.

As a consequence of the AWC, Tangudu comprehends the statutory disqualification, prohibiting him from engaging in any capacity, even clerical or ministerial, with any FINRA member for the duration of the bar. Following FINRA’s approval or acceptance of the agreement, the sanctions outlined in the AWC will start on a specific date.