Banif Securities, Inc. (CRD #38913, New York, New York) submitted a Letter of Acceptance, Waiver and Consent (AWC) in which the firm and Kailer were censured, and the firm was fined $45,000, $20,000 of which was joint and several with Kailer. Without admitting or denying the findings, the firm and Kailer consented to the described sanctions and to the entry of findings that the firm permitted Kailer to actively engage in the management of its investment banking or securities business without being registered as a general securities principal. The findings stated that the firm, acting through Kailer, (i) permitted a representative to conduct a securities business while his registration was inactive due to his failure to timely satisfy the Regulatory Element of the Continuing Education requirement; (ii) failed to maintain all required information for new accounts; (iii) and failed to maintain email correspondence sent or received by Kailer relating to the firm’s business. NASD also found that the firm was unable to produce any written procedures relating to email or instant messaging prior to contracting for electronic storage. (NASD Case #E1020050036-01)