Schiff's Company Had Been Fined For Violating The Same Rule During The Bush Administration. According to the FINRA "letter of acceptance, waiver, and consent" that Schiff signed, FINRA had previously fined Euro Pacific Capital for making a material change in its business without first obtaining consent. From the FINRA letter:
In December 2008, EPC entered into an AWC
with FINRA that imposed a censure and a $37,500 fine for violations of NASD Conduct Rules 3010, 3011 and 2110 and NASD Membership and Registration Rule 1017. ("Rule 1017") The Rule 1017 violation was based on the EPC's failure, from October 13, 2001 through November 28, 2005, to file an application to obtain approval from FINRA for a material change in its business operations.
http://mediamatters.org/research/201109210002