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.

Ladenburg Thalmann & Co., Inc.
AWC/2007009479501

The Firm 

• failed to evidence approval of research reports and to properly disclose securities holdings in research reports; 
• failed to, enforce procedures to ensure compliance with FINRA rules requiring approval of research reports, establish and maintain a supervisory system reasonably designed to ensure that disclosure of securities ownership complied with FINRA rules, promulgate and enforce firm policies and procedures concerning review of employee electronic communications with the public that comported with the standards set forth in FINRA rules; 
• failed to request and receive duplicate statements for employee brokerage accounts in contravention of its policies and procedures;
• was unable to evidence requests or approvals of dual employment for employees as required by its policies and procedures;
• failed to evidence that it conducted annual branch inspections;
• failed to file an accurate Annual Compliance Report for one year;
• failed to report customer complaints;  
• unable to evidence that it timely filed Uniform Termination Notices for Securities Industry Registration (Forms U5) and that its Compliance Registered Options Principal regularly furnished the required options activity reports to the compliance officer and other senior management;
• failed to file an accurate annual attestation regarding NYSE Rule 472; and
• failed to make and keep accurate records of the computation of aggregate indebtedness.

Ladenburg Thalmann & Co., Inc.: Censured; Fined $200,000