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.

Windham Securities, Inc. and Joshua Constantin (Principal)
AWC/2009016318001

Windham and Constantin 

• refused to allow FINRA staff to enter the firm’s branch office to examine the firm’s books and records, and to otherwise conduct an on-site examination;
• failed to respond to FINRA requests for documents and information, and
• have not established the existence of the vast majority of the books and records that the firm is required to make and preserve.

Acting through Constantin, Windham failed to maintain and preserve numerous books and records required pursuant to Securities and Exchange Commission (SEC) Rules 17a-3 and 17a-4, and NASD Rule 3110.

Windham Securities, Inc.: Expelled

Joshua Constantin (Principal): Barred