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.

Paul Arnold Nilssen (Principal)
AWC/2007011308802

Nilssen failed to reasonably supervise his member firm’s operations staff in connection with the issuance and hand delivery of checks to customers. Nilssen was aware of deficiencies but took inadequate steps to address them. Nilssen failed to review the operations staff’s practices or files to ensure that they always obtained forms that brokers completed to request that checks be issued from customer accounts, and receipts customers signed to acknowledge their receipt of hand-delivered checks.

Paul Arnold Nilssen (Principal): Fined $7,500; Suspended 10 business days

Tags: Check