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.

William Walter Spencer Sr.
AWC/2008013442501

Spencer engaged in a Ponzi scheme over a 10-year period, borrowing $1,897,718 from customers and non-customers by inducing them to sign promissory notes, representing that he would pay 10 percent to 12 percent interest and return the investor’s principal in periods ranging from six months to one year. Spencer misused the funds because he knew he did not have the liquid assets or ongoing income necessary to pay interest and return the principal, and used new investor funds to pay existing investors. In other instances, Spencer automatically renewed the obligation when the promissory notes became due. Spencer’s member firm prohibited loans from customers regardless of the registered representative’s relationship with the customer, unless the registered representative obtained prior written approval. Spencer never requested or received approval from his firm to accept the loans. 

William Walter Spencer Sr.: Barred