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.

Robert Allen Pierce (Principal)
AWC/2009020245901

Pierce effected, or caused to be effected, securities transactions in customers’ accounts without their knowledge or consent, and in the absence of written or oral authorization to exercise discretion in those accounts. The transactions included purchases totaling approximately$10,328.37 and sales totaling approximately $54,733.15.

Robert Allen Pierce (Principal): No Fined in light of financial status; Suspended 4 months in all capacities