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.

Teri Sue Shepherd (Principal)
AWC/2009017136101

Acting through Shepherd, her member firm conducted a securities business while failing to maintain adequate net capital. Shepherd caused the firm’s net-capital violations by improperly treating a debt the firm’s parent company owned as an allowable asset for purposes of its net-capital calculations, and improperly treating as allowable the excess amount of concessions receivable for trails over the amount of corresponding commissions payable.

Teri Sue Shepherd (Principal): Fined $7,500; Suspended 45 days in Principal capacity only; Required to requalify by examination before acting in any FINOP capacity with any FINRA registered broker-dealer.

Tags: FINOP  Net Capital