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.

Michael James Dwyer
AWC/2009018215801

Dwyer willfully failed to timely disclose material information on his Form U4. Dwyer completed compliance questionnaires for his member firms in which he falsely stated he understood his obligation to notify the firm of any change to his Form U4, including any liens. One of Dwyer’s firms received credit reports that showed the lien was still outstanding, and the firm’s management and CCO specifically instructed him to disclose the lien on his Form U4, but he failed to do so at that time.

Michael James Dwyer: Fined $5,000; Suspended 3 months