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.

REDACTED (Principal)
OS/2007007795401

REDACTED electronically affixed two customer names to three solicitor disclosure statements without their specific authority, and created an email that was purportedly received from the customer, which he forwarded along with the false disclosure statements to his member firm for processing. By creating a false disclosure statement,REDACTED caused his member firm to violate the requirements of the Investment Advisors Act of 1940 and, by creating the purported email, REDACTED caused his firm’s records to be inaccurate and thereby prevented it from meeting its obligation to preserve, for a period of not less than six years, the first two years in an accessible place, all records required pursuant to SEC Rule 17a-4(b)(4). 

Also, REDACTED engaged in outside business activities and private securities transactions without written notice to, or approval from, his member firm. REDACTED failed to respond to FINRA requests for documents and information. 

REDACTED (Principal): Barred