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.

David A. Noyes & Company
AWC/2005000219101/Fe

The Firm failed to enforce written supervisory procedures, in that it failed 

• to maintain separation between its sales and investment banking departments to prevent communication of material, non-public information concerning investment activity to anyone outside the investment banking department without the prior approval of designated managers; 
• to establish “Grey List” procedures to be implemented when the firm is about to obtain, or has obtained, material, non-public information concerning a security; and 
• to establish a “Restricted List” procedure designed to prohibit insider trading violations and appearances of impropriety. 

The Firm failed to enforce written policies and procedures reasonably designed to prevent the misuse of material, non-public information by the firm or any person associated with it. 

David A. Noyes & Company: Censured; Fined $22,500; Required to revise its supervisory system regarding 

• the misuse of material, nonpublic information by the firm or any person associated with it; 
• maintaining separation between its sales and investment banking departments to prevent communication of material, non-public information; and
• establishing “Grey List” and “Restricted List” procedures.