On November 23, the Financial Industry Regulatory Authority (FINRA) fined Terra Nova Financial, LLC, of Chicago, $400,000 for making more than $1 million in improper “soft dollar” payments to or on behalf of five hedge fund managers.  The broker-dealer did not follow its own policies to ensure the payments were proper, according to FINRA.  We detail the factual background and legal basis for the fine imposed by FINRA.