The allegations read: Mantei was named a respondent in a finra complaint alleging that he willfully violated msrb rule g-17 by circumventing the supervisory system of his member firm while he was seeking to effect a trade between firm customers. The complaint alleges that to comply with the firm's wsps, mantei would have been required to identify each of these transactions as a cross-trade on the firm's order tickets and also to affirmatively justify its fairness in writing. Mantei instead effected each trade in a manner that avoided these requirements. Specifically, mantei arranged for an external third party to buy the selling firm customer's investment with the understanding that mantei would have the firm repurchase it a short time later. After mantei caused the firm to repurchase the investment, he then finally sold it to the buying firm customer. In effecting all of these transactions, mantei failed to comply with the firm's supervisory procedures even though, in substance, each set of transactions amounted to a cross-trade between firm customers.
