NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

William James McCluskey (Principal)
AWC/2009016262301

McCluskey acted in a principal capacity at his member firm without being properly registered as a principal. Although a large percentage of McCluskey’s time was devoted to business development, he was actively engaged in the management of his firm’s investment banking and securities business. Duirng that time period, McCluskey was the firm’s President and Chief Executive Officer, was responsible for all of the firm’s securities and investment banking operations, supervised various registered persons, including the firm’s Chief Financial Officer, a branch manager and managing directors, and was involved in the daily supervision of the firm’s investment banking business.

William James McCluskey (Principal): Fined $15,000; Suspended 10 business days

Tags: Unregistered Principal