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.

Ronald Marvin
AWC/2010021174501

Marvin misused approximately $145,000 in funds obtained from investors in a limited partnership that he owned and controlled.

Marvin established the limited partnership as a general investment fund and referred to it as a hedge fund.  The limited partnership had investors who were Marvin’s long-standing friends/customers. Marvin maintained the limited partnership’s brokerage account at his member firm and made all of the investment decisions for the fund, which primarily involved stock transactions; Marvin was also the registered representative for the limited partnership’s account and received commissions from trades in the account.

The general partner of the limited partnership was another entity Marvin owned and controlled. Under the terms of the limited partnership’s offering memorandum, the limited partnership was required to pay an annual management fee of 1 percent to the other entity Marvin owned and controlled. There was approximately $1 million invested in the limited partnership; therefore, the other entity was only entitled to an annual management fee of approximately $10,000, but Marvin wired approximately $145,000 more from the limited partnership’s brokerage account to the other entity’s bank account and used those funds to pay his salary and other expenses of the other entity. In addition, Marvin had no authority to withdraw the additional $145,000 from the limited partnership’s account; Marvin repaid the limited partnership for the excess funds he had withdrawn from its account.

Ronald Marvin : Barred

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