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.

Hernan Charry Jr. aka Herman Charry (Principal)
AWC/2010022715607

Charry failed to enforce his firm’s WSPs regarding the handling of PPM, subscription documents and investor funds for private placement offerings his firm sold, and he failed to effectively supervise the associated persons’ handling of such documents. 

Hernan Charry Jr. aka Herman Charry (Principal): Fined $10,000; Suspended 20 business days

Tags: WSPs  Supervision  Private Placement  Regulation S-P