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.

Dennis Lee Keating II (Principal)
AWC/2007011125101

Keating participated in private securities transactions involving the offer and sale of interests in a company, outside the scope of his employment with his member firm. Keating sold interests in the company totaling approximately $17.6 million to investors and received compensation in the approximate amount of $1.7 million for his participation. Keating failed to provide his firm with prior written notice of his proposed participation in these transactions and failed to receive the firm’s prior written approval. At all times, the firm’s written procedures prohibited employees from engaging in private securities transactions.

Keating was employed by outside businesses where he held various positions, including officer and director with these outside businesses, while he was associated with his firm, and failed to provide the firm with prompt written notice of these outside business activities.

Dennis Lee Keating II (Principal): Barred