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.

Bennett Joseph Lacour III
2007011010401

Lacour borrowed $5,000 from a customer contrary to his firm’s written supervisory procedures prohibiting registered representatives from borrowing from a customer without prior review and approval by the firm, unless the customer was a familymember or financial institution, which the customer was not. Lacour failed to pay the loan in full and failed to respond to FINRA requests for information. 

Bennett Joseph Lacour III: Barred; Ordered to pay $4,400 plus interest in restitution to customer.