For example, J.P. Morgan failed to move Italian securities to a good control location for nearly two years, and on one sample day, created a deficit in 81 Italian securities worth approximately $146 million. Firms have a fundamental responsibility to safeguard the securities of their customers," said Susan Schroeder, Executive Vice President of FINRA's Department of Enforcement. "The Customer Protection Rule is an important component of investor protection, and member firms must have reasonably designed and maintained systems and procedures to comply with the possession and control requirements. In determining the appropriate monetary sanction, FINRA considered J.P. Morgan's cooperation in undertaking a plan to address the violations and that it over-reserved cash deposits in an effort to protect customers from its failed segregation of securities. In settling this matter, J.P. Morgan neither admitted nor denied the charges, but consented to the entry of FINRA's findings.