FINRA has fined former UBS broker Mark L. Sullivan $10,000 and suspended him for three months after finding he placed 581 unauthorized trades in two customer accounts without written authorization. Sullivan, who worked in New York City at UBS Financial Services, mismarked the trades as unsolicited and falsely told his firm three years running that he exercised no discretion, according to a FINRA report dated August 6, 2026.
What happened
Mark Lawrence Sullivan (CRD# 2531982) placed 581 discretionary trades in two customers’ accounts between January 2021 and June 2024, per the disciplinary findings. Neither the customers nor his firm had granted written approval for that discretion.
Sullivan then mismarked solicited trades as unsolicited on the order tickets. The practice caused UBS to keep inaccurate books and records, and it hid the trading pattern from the firm’s supervisory systems for more than three years.
Key facts from the FINRA action
| Item | Detail |
|---|---|
| Broker | Mark Lawrence Sullivan, CRD# 2531982 |
| Firm | UBS Financial Services Inc., New York, NY |
| Unauthorized trades | 581 in two customer accounts |
| Time period | January 2021 to June 2024 |
| Fine | $10,000 |
| Suspension | Three months, August 2026 to November 2026 |
| Rules cited | FINRA Rules 3260(b), 4511, and 2010 |
| Industry experience | 28 years across 5 firms |
Sullivan consented to the sanctions without admitting or denying the findings. The settlement came through FINRA’s standard acceptance, waiver, and consent process.
Disclosure history on the BrokerCheck record
| Disclosure | Date | Outcome |
|---|---|---|
| Regulatory event | August 2026 | $10,000 fine, three-month suspension |
| Employment separation after allegations | July 26, 2024 | Discharged by UBS Financial Services |
| Customer dispute | Settled October 2024 | $96,565.83 paid, suitability allegations |
The settled dispute spanned investments made between July 13, 2015 and August 14, 2024. The customer alleged the recommended securities were not suitable for a person of his age.
UBS supervision and the Procyon chapter
UBS terminated Sullivan in July 2024 after an internal review found he violated firm policies by exercising discretion without authorization, mismarking tickets, and failing to be forthcoming during the investigation. FINRA opened its own review after UBS filed the required termination notice.
Four months later, Sullivan registered with Procyon, a registered investment adviser backed by Dynasty Financial Partners. Industry reports said he managed roughly $800 million in client assets at the move, and registration records show his Procyon affiliation ended in March 2026.
Red flags investors should catch next time
- Trade confirmations marked unsolicited when the broker initiated the recommendation
- An account that trades frequently with no written discretion agreement on file
- A broker who answers annual compliance questionnaires the same way three years running
- Heavy activity in statements right before quarterly reviews
What investors can do now
Unauthorized discretion is one of the cleaner claims to prove in arbitration, because the paper trail is binary. Either the firm holds written authorization for the account or it does not.
Investors who held accounts handled by Sullivan at UBS should pull their full statements and confirmations from 2021 through 2024 and check the solicited or unsolicited coding on each trade. His public record is available through FINRA BrokerCheck.
Haselkorn & Thibaut fights for investor recovery
Haselkorn & Thibaut is a securities law firm founded by former Wall Street defense attorneys who shifted their practice to represent investors. The firm has recovered over $520 million for clients in securities matters and maintains a 98 percent success rate in resolved nontraded REIT cases. Attorneys are AV Preeminent rated through Martindale-Hubbell, designated as Super Lawyers, and hold a 5.0-star client review average. The firm operates on a contingency basis, so there is no fee without a recovery.
Contact Haselkorn & Thibaut today
Time matters in unauthorized trading cases. The earlier you act, the stronger your position. The firm offers a free case evaluation to assess your losses, review your account history, and explain your options under arbitration or settlement.
- Main Phone: 1-888-885-7162
- website for a free consultation
Offices in Florida, New York, Arizona, Texas, and North Carolina. Former Wall Street defense attorneys with 95+ years of combined experience. No recovery, no fee.
Questions investors ask about Mark L. Sullivan
Who is Mark L. Sullivan? He is a former UBS Financial Services broker in New York City with 28 years in the industry, most recently associated with the adviser Procyon before that registration ended in March 2026.
What did FINRA find? FINRA found Sullivan exercised discretion without written authorization on 581 trades, mismarked them as unsolicited, and falsely reported on three compliance questionnaires that he used no discretion.
Can UBS customers recover losses from the unauthorized trading? Customers may pursue arbitration claims against the firm for failing to supervise the account activity, and prior disputes on the record have settled. A securities attorney can review the specific account history.
This article is for informational purposes only and does not constitute legal advice.
You can also read Unauthorized Trading: How Brokers Execute Trades Without Consent and Drain Retirement Accounts and Axos Clearing and Worden Capital Face $40.7 Million FINRA Arbitration Over Supervisory Failures.
