December 31, 2018 – An OHO decision became final in which Harrington was barred from association with any FINRA member in all capacities, ordered to pay $105,000, plus interest, in restitution to his member firm and ordered to pay disgorgement in the amount of $190,974.64, plus interest, to FINRA. The sanctions were based on the findings that Harrington converted customer funds, intentionally causing the customer to wire $19,874.64 of her funds into his account. The findings stated that Harrington took the funds for his own use, without the customer’s authorization, and never returned them. The findings also stated that Harrington attempted to obstruct FINRA’s investigation into his conversion by contacting the customer and asking her to sign a false document stating that she had stayed at his vacation rental property. The findings also included that Harrington engaged in private securities transactions, for which he was compensated, without giving prior notice to or receiving prior written approval from his firm and without the firm’s supervision. FINRA found that Harrington made misstatements and provided false documents to his firm in connection with its investigation into whether he had engaged in outside business activities. Harrington intentionally misrepresented the nature of payments he received and deposited into his bank accounts as rental income and a payment from his former broker dealer. In fact, the payments were for the purchase of stock in Harrington’s outside business. Harrington knowingly caused falsified rental contracts to be sent to his firm in order to conceal the true purpose of the funds he had received. FINRA also found that Harrington provided false and misleading documents and information to FINRA in connection with its investigation of the private securities transactions and the conversion. Harrington produced a bank statement to FINRA that his sales assistant, under his direction, altered to remove a customer’s name as the originator of a wire transfer. Harrington also submitted a written response to FINRA that falsely represented that he was entitled to the funds he directed the customer to wire to him, claiming it was payment for investment advisory fees rendered to the customer. Harrington also falsely testified that the purported rental agreements with another customer were authentic and represented legitimate rental transactions. See, FINRA Case #2015047303901.