Stirlingshire Investments

ChapmanAlbin is investigating Stirlingshire Investments (CRD 310576), a New York-based broker-dealer. In January 2026, FINRA found that the firm failed to establish and enforce a reasonable supervisory system for its brokers’ recommendations of inverse and leveraged exchange-traded funds — complex products that FINRA has long cautioned are typically not appropriate for retail investors who plan to hold them longer than a single trading day. Three registered representatives at the firm recommended these products to more than 25 retail customers during a period when the firm had no adequate procedures to ensure those recommendations complied with Regulation Best Interest. FINRA also found that the firm failed to file required offering materials with regulators for two private placement offerings — sold to 21 investors — that were issued by the firm’s own parent company. Stirlingshire was censured and fined $40,000. This page is based on public records including FINRA BrokerCheck and FINRA disciplinary records.

If you invested in leveraged or inverse ETFs or private placements through Stirlingshire Investments and lost money, this page explains what the public record shows and what options may be available to you.

Firm Snapshot

CRD: 310576
Location: New York City, NY (15 W 38th St, Suite 704)
FINRA BrokerCheck: View Stirlingshire Investments on BrokerCheck
Primary concern: Failure to supervise NT-ETF recommendations to retail customers; failure to file private placement offering materials with FINRA
Products mentioned in public records: Inverse and leveraged ETFs (NT-ETFs); private placements
Regulatory action: Censured, fined $40,000, required to complete compliance undertaking
FINRA Case: 2023077093401

Key Facts and Public Records

• FINRA Letter of Acceptance, Waiver, and Consent (AWC), Case No. 2023077093401, accepted January 22, 2026
• FINRA BrokerCheck Detailed Report for Stirlingshire Investments (CRD 310576)
• Stirlingshire has been a FINRA member since June 2022 and is headquartered in New York with approximately 26 registered representatives
• From November 2022 through April 2024, three Stirlingshire registered representatives recommended inverse and leveraged ETFs to more than 25 retail customers
• The firm’s written supervisory procedures (WSPs) actually prohibited NT-ETF purchases in customer accounts — but the firm did not enforce that prohibition and put no monitoring tools in place to catch violations
• From June 2022 through December 2023, a registered representative sold two private placement offerings issued by the firm’s parent company to 21 investors without the firm filing the required offering materials with FINRA
• The firm did not file those private placement materials until December 2025 — more than two years after the last sale
• Stirlingshire was censured, fined $40,000, and required to certify within 90 days that it has remediated its supervisory failures

More Info

BrokerCheck and registration summary

Stirlingshire Investments (CRD 310576), doing business as Stirlingshire BD LLC, is a full-service broker-dealer headquartered in New York City and primarily serving retail customers. The firm has been registered with FINRA and the SEC since June 2022 and is currently approved in all 53 U.S. states and territories. It has approximately 26 registered representatives. Investors can review the firm’s full registration history, disclosure record, and current status on FINRA BrokerCheck. The firm’s BrokerCheck report reflects one final regulatory disclosure — the FINRA action described on this page.

Regulatory and enforcement actions

FINRA accepted the AWC on January 22, 2026. Stirlingshire was censured and fined $40,000. As part of the settlement, the firm agreed to an undertaking requiring a senior management registered principal to certify in writing, within 90 days, that the firm has remediated the identified deficiencies and implemented a supervisory system reasonably designed to comply with Reg BI and applicable FINRA rules regarding NT-ETFs. The action originated from a FINRA routine cycle examination of the firm.

What FINRA found

FINRA’s findings cover two separate but related compliance failures.

The first involves inverse and leveraged ETFs — a category of complex products designed to amplify or invert the daily return of an underlying index. Because of how these products work, they can behave in unexpected ways when held for more than a single trading day, particularly in volatile markets. FINRA has cautioned since 2009 that these products are typically not suitable for retail investors who plan to hold them longer than one session. Stirlingshire’s own written procedures reflected that concern — they explicitly prohibited NT-ETF purchases in customer accounts and instructed supervisors to cancel them. Yet FINRA found the firm never enforced that prohibition and never put in place any alerts, exception reports, or other tools to identify when such recommendations were being made. Three registered representatives recommended these products to more than 25 retail customers during an 18-month period with no meaningful oversight.

The second involves private placements. FINRA rules require firms to file private placement offering materials with FINRA before or at the time those materials are given to potential investors. Stirlingshire failed to do this for two private placement offerings issued by its own parent company — offerings that a firm representative sold to 21 investors. The firm did not file the required materials until December 2025, roughly two years after the last sale took place.

What this could mean for investors

Failure to supervise is at the core of what FINRA found here. When a firm has written rules on the books but no mechanism to enforce them, the practical effect is that customers bear the risk of the firm’s internal breakdown. Retail investors who purchased inverse or leveraged ETFs through Stirlingshire may have held those products in ways that were inconsistent with their investment goals — and the firm had no system in place to catch that problem.

Regulation Best Interest sets a clear standard: broker-dealers must act in the best interest of retail customers when making recommendations. FINRA found Stirlingshire lacked the supervisory infrastructure to achieve compliance with Reg BI’s Care Obligation for NT-ETF recommendations. That is not a paperwork issue — it means retail customers were receiving recommendations without the firm-level review that Reg BI requires.

For the 21 investors who purchased private placements issued by the firm’s own parent company, the failure to file required offering materials raises additional concerns. Investors in private placements generally have limited ability to resell their interests and bear meaningful risk. The regulatory protections that come with proper filing are not a formality — they exist to ensure regulators can monitor whether investors are receiving accurate and complete information.

If you purchased leveraged or inverse ETFs or private placements through Stirlingshire and experienced losses, you may have options to pursue recovery. ChapmanAlbin works on contingency, meaning there is no cost to you unless we recover money on your behalf. The first step is a free, no-obligation consultation with one of our attorneys.

Common Warning Signs

• Your broker at Stirlingshire recommended a leveraged or inverse ETF without explaining that it was designed for short-term trading and could perform very differently from what you expected if held for more than a day.
• You held an inverse or leveraged ETF in your account for weeks or months and experienced losses you did not anticipate given what your broker told you about the investment.
• You were not asked meaningful questions about how long you planned to hold the investment or how much short-term volatility you could tolerate.
• You purchased what was described as a private placement through Stirlingshire, particularly one connected to the firm’s parent company, and received limited or unclear information about the offering.
• You had difficulty getting information about the value of your private placement, your exit options, or when you could expect a return.
• Your account statements reflected losses on products your broker described as appropriate or consistent with your investment goals.

Documents to Gather

• Account statements for the full period you had accounts at Stirlingshire Investments
• Confirmation statements for any purchases of ETFs, leveraged or inverse funds, or private placements
• Any written recommendations, proposals, or sales materials related to the products you purchased
• New account forms or suitability questionnaires you completed when opening your account
• Private placement memorandums, term sheets, or other offering documents you received
• Emails, letters, or notes from conversations with your broker or the firm about any of these investments
• Any correspondence from Stirlingshire, FINRA, or the issuer of any private placement about your account or holdings

FAQs

What did FINRA find against Stirlingshire Investments?

FINRA found that Stirlingshire failed to establish and enforce a supervisory system for its brokers’ recommendations of inverse and leveraged ETFs, despite having written procedures that actually prohibited those purchases. Three registered representatives recommended these complex products to more than 25 retail customers without any firm-level oversight. FINRA also found that the firm failed to file required offering materials with FINRA for two private placements issued by its parent company — materials that were not filed until roughly two years after the last sale. The firm was censured and fined $40,000.

What are inverse and leveraged ETFs, and why are they a concern for retail investors?

Inverse and leveraged ETFs are designed to deliver a multiple of — or the opposite of — the daily return of an underlying index. Because they reset daily, their performance over longer holding periods can diverge sharply from what an investor might expect based on the underlying index’s movement. FINRA has specifically cautioned since 2009 that these products are typically not appropriate for retail investors who plan to hold them for more than one trading session. The concern is not just losses — it is that the product behaves in ways that most investors do not anticipate when they purchase it.

What is the concern with private placements sold by a firm’s parent company?

Private placements are investments in unregistered securities, meaning they carry fewer regulatory disclosures than publicly traded investments and are generally illiquid. When a firm sells private placements issued by its own parent company, there is an inherent conflict of interest — the firm’s representatives have an incentive to recommend the offering regardless of whether it fits the investor’s goals. FINRA rules require offering materials to be filed before investors receive them, so that regulators can monitor the process. The failure to file those materials here means that basic oversight mechanism did not function for these 21 investors.

Do I have a claim if I still hold the investment?

Potentially. Whether you have grounds for a claim generally depends on whether the recommendation was appropriate for your financial situation at the time it was made — not whether you still hold the investment or what its current value is. If the product was not suitable for your goals, risk tolerance, or investment timeline when it was recommended, that mismatch may support a claim regardless of where things stand today.

How does ChapmanAlbin handle these types of cases?

ChapmanAlbin works on contingency. If we take your case and do not recover money for you, you owe us nothing. There is no upfront fee and no cost to speak with one of our attorneys in a free initial consultation.

Disclaimer

This page is for informational purposes only and does not constitute legal advice. The information presented is based on publicly available records including FINRA BrokerCheck and FINRA disciplinary filings. Past outcomes are not a guarantee of future results. Every matter depends on its own facts and circumstances and should be evaluated individually. This site contains attorney advertising. Any reference to past cases or successes should not be construed as a guarantee of any future outcome.