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.

Jerry Perlman
AWC/2008011707002

While exercising control over the trust account for the benefit of an elderly customer, and while acting with the requisite scienter, Perlman excessively traded the account in a manner that was inconsistent with the customer’s investment objectives, financial situation and needs. Perlman recommended transactions to the customer without having reasonable grounds for believing that such transactions were suitable in light of the frequency of such transactions, the level of margin used in the account, and the customer’s financial situation, investment objectives and needs. Perlman’s trading, for the life of the account, resulted in losses of approximately $551,000 and generated gross commissions of approximately $118,000 and margin interest of approximately $9,300.

Jerry Perlman : Barred

Tags: Elderly