Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2010
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.
Denis William Kraemer Jr.
2006006192901
The NAC imposed the sanctions following appeal of an Office of Hearing Officers (OHO) decision. The sanctions were based on findings that Kraemer willfully failed to disclose material information on his Forms U4.
Denis William Kraemer Jr.: Fined $5,000; Suspended 9 months
Bill Singer's Comment
It appears that the NAC sustained the OHO's findings and sanctions. Specifically, the Hearing Panel found that Kraemer did not reveal that he had been charged with criminal possession of stolen property and charged with, and convicted of, petit larceny — misdemeanors that involve the wrongful taking of property. The Hearing Panel concluded that Kraemer’s failure to disclose the charges and conviction was willful, that the omitted information was material, and that Kraemer is statutorily disqualified.
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