X will be non-registered and not dealing with investing public. Firm’s disciplinary history does not go to issue of inadequate supervision.
UNDERTAKINGS
1. Although X will not be in the same physical location as the supervisor, he will be subject to telephone meetings on a monthly basis. These discussions will focus on meetings that have taken place between X and prospective clients. X will also visit the home office, at least once, on an annual basis.
2. X will not have any direct dealings with the investing public.
3. X's outgoing correspondence and expenseswill be reviewed by the Proposed Supervisor.
4. Based upon the nature of his conviction, the Sponsoring Firm will require X to provide a copy of his personal taxes to be reviewed by either the Firm's CFO or its auditors.
5. For the duration of X's statutory disqualification, the Firm must obtain prior approval from Member Regulation if it wishes to change X's responsible supervisor from the Proposed Supervisor to another person.