Xís disqualification occurred 9 years ago without recurrence. Proposed supervision adequate, notwithstanding SD exam issue in 2000 (specific note taken of replacement of supervisor). X and Proposed Supervisor not related by blood or marriage.
1. X will conduct securities business on behalf of the Sponsoring Firm only from the office where Proposed Supervisor 2 is physically located;
2. X will act as a principal, specifically involved with sales training and supervision of registered representatives;
3. The supervisory procedures of the Sponsoring Firm shall be amended clearly to establish Proposed Supervisor 2's responsibility to supervise X. In Proposed Supervisor 2's absence, X will be supervised by Proposed Supervisor 3;
4. X will not maintain discretionary accounts at any time;
5. The review of New Account Forms will include a review for suitability;
6. Proposed Supervisor 2 will review and approve all of X's order tickets on a daily basis. Proposed Supervisor 2 will review X's incoming and outgoing correspondence at the time that they are either received or sent;
7. Proposed Supervisor 2 will keep a written record evidencing review and approval of all of X's transactions, the opening of new accounts, and all correspondence;
8. X will be prohibited from accepting funds from customers in his name. Rather, all funds must be payable to either the Firm or the particular fund. The Firm will develop a procedure to compare X's customer requests for disbursement to monthly statements;
9. All complaints pertaining to X, whether verbal or written, will be immediately referred to Proposed Supervisor 2 for review, and then to the Firm's Director of Compliance. Proposed Supervisor 2 will prepare a memorandum to the file as to what measures he took to investigate the merits of the complaint (e.g., contact with the customer) and the resolution of the matter. Documents pertaining to these complaints should be kept segregated for ease of review;
10. X will be required to attend an annual compliance meeting, and evidence of his attendance will be kept segregated in a file for easy review; and
11. For the duration of X's statutory disqualification, the Sponsoring Firm must obtain prior approval from Member Regulation if it wishes to change X's responsible supervisor from Proposed Supervisor 2 to another person.