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.

Allan J. Satterfield
OS/2005001398602

Acting with others, Satterfield  participated in a fraudulent scheme to solicit investments in an unregistered hedge fund and its general partner and, in doing so, engaged in a variety of fraudulent and deceptive sales practices, disregarding his duties and obligations of fair dealing to his customers. Satterfield knew, or was reckless in not knowing, that the hedge fund was engaging in a highly speculative trading strategy involving futures contracts, and that information the hedge fund manager supplied and used to solicit customers contained materially false and misleading statements and omissions. Satterfield ignored many red flags, including those in the hedge fund’s private placement memorandum. Satterfield solicited customers without conducting a reasonable investigation to determine whether the hedge fund and its general partner were suitable investments, and without regard as to whether his customers were capable of evaluating and bearing the risks associated with the investments.

Allan J. Satterfield : No Fine in light of financial status; Suspended 6 months

Tags: Hedge Fund