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.

Name Redacted
AWC/2007009784401

NEWSLETTERS

• XXX distributed newsletters that a principal of his member firm had not approved for distribution, thereby preventing his firm from complying with NASD Rule 2210(C)(1) by providing the newsletters to FINRA’s Advertising Regulation Department for approval; 
• the newsletters failed to prominently disclose the firm’s name as the broker-dealer through which he conducted his securities business; and 
• one of the newsletters referenced an unregistered entity through which XXX engaged in business but did not disclose the relationship between his firm and the unregistered entity. 

SEMINARS

• XXX distributed invitations to seminars about financial matters, including investments, and a firm principal had not approved the content of the invitations;
• the invitations and XXX’ Web site misrepresented that he was the author of books; 
• the invitations contained misleading and exaggerated information and failed to identify his firm as the broker-dealer. 
• XXX conducted seminars at which he made publications available for review, and offered to distribute the publications that were purchased from a vendor of investment publications, which a principal of his firm had not approved, and thereby prevented his firm from complying with NASD Rule 2210(C)(1) by providing the newsletters to FINRA’s Advertising Regulation Department for approval;
• XXX offered to distribute the publications on his public Web site. The publications contained violations of the content standards in FINRA Rules 2210(d)(1) and (2) and included statements that were misleading, inaccurate or unwarranted; and
• XXX used a script in presenting material at the seminars that was outdated and misleading. 

Name Redacted : Fined $15,000; Suspended 6 months