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 Adam Lichtenstein
AWC/2009016157803

Lichtenstein solicited firm customers to invest in a private placement offering of securities and sent several customers a one-page document entitled “use of proceeds” for an entity that was not the offering’s issuer. The document had been prepared by Lichtenstein’s firm’s outside counsel and the firm provided the document to Lichtenstein for distribution to prospective investors. While some of the proceeds from the offering were ultimately used to purchase membership interests in the other entity, the offering was not for the other entity. Although Lichtenstein never owned any interest in his firm, he represented to a customer that he did have an ownership interest in the firm. 

Michael Adam Lichtenstein: Fiend $50,000; Suspended 24 months in all capacities

Tags: Private Placement