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.

Thomas Colby Cantrell
AWC/2009016709021

Cantrell participated in sales of universal lease programs (ULPs) totaling $763,888.82 to members of the public, failed to provide his member firm with written notice about the sales and failed to obtain the firm’s written approval.

Cantrell provided false information to his firm.  He completed and submitted an outside business activities questionnaire form in which he falsely stated he conducted no business using a DBA (doing business as), falsely responded whether any other company or individual employed him, falsely disclosed that he was not involved with outside business activities, and answered “yes” that he was aware he could not engage in outside business activities or private securities transactions, directly or indirectly, without prior written firm approval.

Cantrell participated in a sale of a total of $210,547.05 worth of ULPs to individuals at another member firm and failed to provide the firm with written notice about the sales or obtain the firm’s written approval. Cantrell received approximately $94,070 in commissions from his sale of the ULPs while registered with both firms.

Thomas Colby Cantrell: In light of Cantrell’s financial status, no fine was imposed; Suspended 12 months

Tags: Universal Lease Programs