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.

Kenneth Richard Campbell III (Principal)
AWC/2010024997001

Campbell failed to enforce his member firm’s heightened supervisory procedures with respect to one of its representatives. 

According to those procedures, Campbell was responsible for determining the scope of the heightened supervision and ensuring that the representative’s supervisor was enforcing the heightened supervision plan. The firm required that the plan be individualized based on the representative’s disciplinary history. Campbell placed a representative on heightened supervision because of his disciplinary history, and the plan Campbell prepared was deficient because it was not tailored to that representative’s history of engaging in private securities transactions and did not provide for any material additional supervision beyond the usual steps that were taken to oversee other firm representatives. Campbell failed to ensure that the plan was implemented and, as a result,the following actions that were required pursuant to the plan were not undertaken:

• a log was not created of the representative’s trades,
• certifications were not made to the compliance department that the heightened supervision plan was implemented, and
• and an annual review of the plan did not take place.

Kenneth Richard Campbell III (Principal): Fined $5,000; Suspended 1 month in Principal capacity only.

Tags: Supervision  Heightened Supervision