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.

George Stephen Conwill (Principal)
AWC/2005003644601

Conwill approved prior to execution, the sale (purchase) of securities to (from) customers where the firm, through other employees, failed to sell (buy) such securities at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each security at the time of the transaction, the expense involved and that the firm was entitled to a profit. The excessive markups and markdowns totaled $1,254,239 for the transactions; in some of the transactions, the markups and markdowns exceeded 10 percent and some of the transactions were for the accounts of a high-net-worth senior customer of the firm. Conwill neither directed any firm employees to disclose, nor did he disclose, the markups and markdowns to the firm’s customers. Conwill failed to take reasonable steps to ensure that the firm established and maintained an adequate supervisory system, and he otherwise failed to reasonably and properly supervise the firm and its registered representatives to detect and prevent violations of NASD Rules 2110 and 2440, and NASD Interpretative Material 2440.

George Stephen Conwill (Principal): Barred

Tags: Mark-Up Mark-Down