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.

Steven William Sauer
AWC/2008014156001

Sauer's compensation arrangement with his member firm included a split of all investment advisor (IA) fees received, for which Sauer received 90% and the firm received the remaining 10%. Further, the firm’s procedures required that all customer checks for payment of such fees be made payable to the firm. Sauer received checks totaling $51,500 in IA fees from customers made payable to him. Sauer deposited the checks into his personal and business checking accounts, did not timely inform his firm of these payments, but later confessed that he had improperly withheld the firm’s portion of those payments, and repaid the firm $5,150.

Steven William Sauer : Barred

Tags: Investment Advisor