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.

Perrin, Holden and Davenport Capital Corporation, dba PHD Capital
AWC/2007008158601

Although it had an established Customer Identification Program (CIP), its internal controls for ensuring compliance were not sufficient to detect or prevent multiple failures to obtain and verify required customer identification information.The Firm failed to obtain required customer identification information for certain accounts, failed to confirm that sufficient documentary and/or non-documentary verification information was obtained prior to approving the accounts, and failed to restrict transactions in certain deficient accounts 30 days o rmore after opening.

Perrin, Holden and Davenport Capital Corporation, dba PHD Capital: Censured, Fined $30,000; Required to have its registered representatives register for three hours of AML training within 60 days of issuance of this AWC, and complete such training within six months of issuance of this AWC.

Tags: CIP