based on the following factors: the seriousness and recentness
of the disqualifying event and the fact that the conduct involved fraud and dishonesty;
the fact that X will be on supervised release until 2004
; and the inadequacy of the Firm's supervisory plan, given the fact that, as proposed, it failed to provide for daily, onsite supervision
. Member Regulation noted that because X was recently convicted for conduct involving deception and dishonesty, offsite supervision was unacceptable.
At the eligibility hearing, the Proposed Supervisor acknowledged Member Regulation's concern with the proposal that X be supervised offsite and agreed to revise the Firm's supervisory structure to provide for onsite supervision. Notwithstanding the Proposed Supervisor's agreement to supervise X onsite, Member Regulation did not amend its original recommendation that the Application be denied.