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FMS Global Strategies told to file missing L2 reports; $500 penalty mostly suspended
Summary
FMS Global Strategies was found to have failed to file 2025 L2 reports. The chair imposed a $500 penalty, suspended $400 if all missing reports are filed within 30 days and there are no violations for four years, leaving $100 payable if conditions are met.
In case 186648, staff recommended a finding that FMS Global Strategies failed to timely file one or more L2 reports for 2025; the firm had not filed the missing reports as of the hearing date. Ms. Fillmore Sardinas, speaking for the respondent, said the organization had settled with a consultant who failed to file the reports and expected to obtain and submit the information “probably within the next couple of days.”
Chair Jay Leach found a violation and imposed a $500 penalty, suspending $400 conditioned on all missing reports being filed within 30 days and no future violations during a four-year period. If those conditions are met, the payable amount will be $100. The chair advised that respondents should ensure notices and multifactor authentication reach responsible staff to prevent missed filings in the future.
