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.

Richard Bert Howes
AWC/2011026308301

Howes participated in a securities transaction without providing prior written notice to his member firm of the proposed transaction and his role therein. Howes referred a customer to a company to invest in a debenture, and based on his referral, the customer invested $50,000 in a debenture and lost his entire investment; Howes received $1,000 for the referral of the customer to the company.

Richard Bert Howes : Fined $6,000 (includes $1,00 disgorgement); Suspended 2 months