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.

Martin Dean White Sr. (Principal)
AWC/2008012577601

As President of his member firm, White permitted the creation and dissemination of misleading sales and advertising materials to various state securities regulators in an effort to draw scrutiny to a business established by former registered representatives who left the firm to start their own business selling oil and gas interests. White made it appear as if the documents had been generated by an entity the former registered representatives established. A firm employee drafted and assembled the mailings to create the appearance that an officer or employee of the former registered representatives’ new business had generated and authorized the mailings. The mailings contained a cover letter drafted to draw regulators’ interest to the former registered representatives’ entity.

The mailings appeared to be from the former registered representatives’ entity, listed the name of an officer or employee of the entity, contained a return address of the entity on the envelopes used in the mailings, included printouts from the entity’s website, provided an executive memorandum, and also provided a “Confidential Private Placement Memorandum” and “Subscription Agreement” which both listed the former registered representatives’ new business throughout the documentation.

Martin Dean White Sr. (Principal): Fined $5,000; Suspended 3 months

Tags: Impersonation  Communications