Kennedy entered the securities industry in 1986 and became registered with Woodbury Financial Jan. 26, 2007, according to FINRA. On March 31, the firm filed a Form U5 disclosing Kennedy was terminated, explaining that he was "permitted to resign for engaging in an unapproved outside business activity involving a financial transaction with a couple of clients," the FINRA AWC letter said, quoting Woodbury.
FINRA initiated an investigation into Kennedy in April 2019 based upon a tip, it said in the letter, without giving any details about that tip. In connection with the investigation, FINRA sent requests to Kennedy May 6, Aug. 6 and Aug. 29, 2019, for the production of documents and information, according to the FINRA letter. "Kennedy provided partial but incomplete responses to these requests," FINRA said.
In December 2019, Kennedy appeared for testimony but "ceased cooperating with FINRA's investigation in March 2020," according to the letter. "In particular, he refused to respond to a March 20, 2020 request" that called for the production of the documents and information that Kennedy had failed to provide in response to the three 2019 requests as well as new documents and information, FINRA said. "As stated during his counsel's phone call with FINRA staff" on March 25, 2020, the respondent acknowledged that he received FINRA's request and would not produce the information or documents requested, it said.
By refusing to cooperate as requested, Kennedy violated FINRA Rules 8210 (governing the provision of information and testimony) and 2010 (governing standards of commercial honor and principles of trade), FINRA said.
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