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.

Bear Stearns & Co., Inc., nka J.P. Morgan Securities, Inc. and Renee Michelle Fourcade
AWC/2006006804401

The Firm shared portfolio trading commissions with Fourcade in violation of Rule 2830(k)’s prohibition against sharing investment company portfolio trading commissions with sales personnel involved in the retail sale or distribution of investment company shares. Notwithstanding its awareness of the payments, the Firm failed to supervise the arrangement and the payments thereunder, and failed to ensure compliance with FINRA directed brokerage rules. 

Bear Stearns & Co., Inc., nka J.P. Morgan Securities, Inc.: Censured; Fined $225,000

Renee Michelle Fourcade: Censured; Fined $15,000