Former UBS advisor Mark Lawrence Sullivan becomes eligible to return to the securities industry on November 6, when the three-month FINRA suspension tied to 581 unauthorized discretionary trades in customer accounts comes to an end. FINRA imposed the suspension and a $10,000 fine in an August settlement.
What FINRA found
FINRA accepted a Letter of Acceptance, Waiver and Consent with Sullivan on August 6, 2026, in case number 2024083156201. Investigators found that between January 2021 and June 2024, Sullivan exercised discretion without prior written authorization in connection with 581 transactions in accounts held by two customers.
The customers allowed Sullivan to trade without calling them first. But they never provided written authorization, and UBS never accepted the accounts as discretionary. Sullivan also mismarked all 581 trades as unsolicited, which caused his firm to keep inaccurate books and records.
On three annual compliance questionnaires, Sullivan falsely stated that he had not exercised discretion in customer accounts. FINRA found the conduct violated Rules 3260(b), 4511, and 2010.
Sanctions and key dates
| Item | Detail |
|---|---|
| Broker | Mark Lawrence Sullivan, CRD# 2531982 |
| Former firm | UBS Financial Services Inc., New York |
| Trades at issue | 581 discretionary transactions, January 2021 to June 2024 |
| Fine | $10,000 |
| Suspension | Three months in all capacities, August 6 to November 6, 2026 |
| AWC number | 2024083156201, accepted August 6, 2026 |
| Rules violated | FINRA Rules 3260(b), 4511, and 2010 |
The UBS separation and what followed
UBS ended the relationship first. The firm discharged Sullivan on July 26, 2024, after an internal review concluded he violated firm policies by exercising discretion and mismarking trade tickets. The Form U5 disclosure on his record states that he “was not forthcoming during the investigation.”
Sullivan later joined Procyon, a wealth management firm backed by Dynasty Financial Partners, according to industry publication AdvisorHub. His BrokerCheck report also lists a customer dispute alleging unsuitable investments.
Why written authorization matters
Brokers generally need two things before trading a customer’s account without prior approval for each order: written authorization from the customer and written acceptance of the account as discretionary by the firm. The requirement lets firms supervise the trading and gives customers a clear record of what authority the broker holds.
Investors who want an advisor to trade on their behalf should sign that written authorization and confirm the firm has accepted the account as discretionary. Verbal permission alone leaves no supervisory trail.
What affected investors can do now
Customers who held accounts with Sullivan at UBS between 2021 and 2024 can request their full trade history and look for transactions they did not authorize. FINRA arbitration claims are generally subject to a six-year eligibility period, so older trades may still be pursued. Investors can review Sullivan’s regulatory record through BrokerCheck using CRD number 2531982.
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This article is for informational purposes only and does not constitute legal advice. Case details are drawn from public FINRA disciplinary documents.
