RRBDLAW.COM -- 917-520-2836 -- Continuing Education

THIS WEBSITE MAY BE DEEMED AN ATTORNEY ADVERTISEMENT OR SOLICITATION IN SOME JURISDICTIONS. AS SUCH, PLEASE NOTE THAT THE HIRING OF AN ATTORNEY IS AN IMPORTANT DECISION THAT SHOULD NOT BE BASED SOLELY UPON ADVERTISEMENTS. MOREOVER, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. NEITHER THE TRANSMISSION NOR YOUR RECEIPT OF ANY CONTENT ON THIS WEBSITE WILL CREATE AN ATTORNEY-CLIENT RELATIONSHIP BETWEEN THE SENDER AND RECEIVER. WEBSITE SUBSCRIBERS AND ONLINE READERS SHOULD NOT TAKE, OR REFRAIN FROM TAKING, ANY ACTION BASED UPON CONTENT ON THIS WEBSITE. THE CONTENT PUBLISHED ON THIS WEBSITE REPRESENTS THE PERSONAL VIEWS OF THE AUTHOR AND NOT NECESSARILY THE VIEWS OF ANY LAW FIRM OR ORGANIZATION WITH WHICH HE MAY BE AFFILIATED. ALL CONTENT IS PROVIDED AS GENERAL INFORMATION ONLY AND MUST NOT BE RELIED UPON AS LEGAL ADVICE. CONTENT ON THIS WEBSITE MAY BE INCORRECT FOR YOUR JURISDICTION AND THE UNDERLYING RULES, REGULATIONS AND/OR DECISIONS MAY NO LONGER BE CONTROLLING OR PERSUASIVE AS A MATTER OF LAW OR INTERPRETATION.

STANDARD DESCRIPTION	KEY
knowingly and intentionally entered priced limit orders in NASDAQ securities for his own account into an electronic communications network (ECN) at prices that her knew would improve, and were intended to improve, the National Best Bid or Offer (NBBO) in such securities, in that the full price and size of such orders would be reflected in the public quotation system as the best prices and sizes at which a market participant was willing to buy or sell such securities.	IMPROVE
knowingly and intentionally entered orders to buy or sell shares of such securities in his trading account at his member firm because he knew, and intended, that they would be routed to market makers whose automated execution systems were programmed to buy or sell, and did buy and sell, such securities on an automated basis at prices equal to the NBBO and in an amount greater than the NBBO.	AUTOEX

Garden State Securities, Inc., George Kenneth Bicking , and Paul William Ponn (AWC/CMS040148/November 2004)
Ponn entered small buy (sell) orders into an electronic communications network (ECN) at prices that affected the national best bid (offer) (NBBO) to facilitate the automatic execution of larger sell (buy) orders on the opposite side of the market by a market maker that guaranteed that they would provide executions at the NBBO price, thereby permitting Ponn to buy (sell) shares at an improved price. Bicking failed to establish, maintain, and enforce a supervisory system reasonably designed to detect and prevent fraudulent, manipulative, and deceptive quotation and trading activity. The firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws, regulations, and NASD rules concerning fraudulent, deceptive, and manipulative quotation and trading activity.
Garden State Securities, Inc., Censured; fined $20,000 jointly and severally with Bicking; Required to revise the firm’s written supervisory procedures regarding quotation and trading activity within 30 business days	George Kenneth Bicking Fined $20,000 jointly and severally with Garden State; Suspended 15 business days in principal capacity	Paul William Ponn Fined $25,000; Suspended 90 days in all capacities