Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
OUTSIDE BUSINESS ACTIVITIES
2009
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.
December 2009
Eldredge participated in private securities transactions without giving prior written notice to,or obtaining prior written approval from, his member firms.With respect to one of those private securities transactions, Eldredge’s investment recommendation was unsuitable in that the customer funded the transaction by mortgaging his personal residence. Eldredge engaged in outside business activities without providing prompt written notice to one of his member firms.Eldredge failed to provide FINRA with requested documents.
David Richard Eldredge (Principal): Barred
Martin Luther Royster
OS/2007010688401
Royster engaged in outside business activities, for compensation of approximately $99,000, without providing prompt written notice to his member firm.
Martin Luther Royster: Fined $5,000; Suspended 3 months
Michael Andrew Betten
AWC/2008013430901
Betten engaged in outside business activities, for compensation of approximately $251,616.18, without providing prompt written notice to his member firm on the annual certification statement or in any other written form. Betten falsely asserted on annual certification statements that he was not engaged in any undisclosed outside business activities.
Michael Andrew Betten: Fined $10,000; Suspended 4 months in all capacities
Leggett engaged in private securities transactions with member firm customers and failed to give written notice to, and receive written acknowledgment from, his member firm. Leggett inaccurately answered questions on his firm’s questionnaires regarding his outside business activities.
Raymond Francis Leggett III: Fined $5,000; Suspended 6 months
Thomas Earl Brand
AWC/2008013307301
Brand engaged in an outside business activity, and received $13,950 in commission, contrary to his member firm’s rules and procedures. Brand also completed an outside business activity form stating that he had no outside businesses to report. He failed to respond, and respond completely, to FINRA requests for information and failed to appear for a FINRA on-the-record interview.
Thomas Earl Brand: Barred
FINRA's National Adjudicatory Council (NAC) imposed the sanctions in a remand decision after Sears had appealed a NAC decision to the SEC. The NAC based its sanctions on findings thatSears effected unauthorized securities transactions in customer accounts andparticipated in outside business activities without providing written notice to her member firm.
Wanda Pittman Sears: No Fine in light of financial status; Suspended 6 months for unauthorized trading; Suspended 6 months for engaging in outside business activity (suspensions to be served concurrently)
Tags: NAC  
Bill Singer's Comment
See this link http://www.brokeandbroker.com/index.php?a=blog&id=66 for more background on the this case.
November 2009
Dennis Brown
2007010450601
Brown engaged in outside business activities without providing written notice to his member firm, and failed to respond to FINRA requests for information.
Dennis Brown: Barred
Jessica Ann Condosta
AWC/2008012820401
Condosta engaged in an outside business activity, for compensation, and failed to provide prompt written notice to her member firm.
Jessica Ann Condosta: Fined $5,000; Suspended 30 days in all capacities
Kerry Lamont Hairston
AWC/2008014418801
Hairston engaged in outside business activities, for compensation, without given prompt written notice to hismember firm.
Kerry Lamont Hairston: Fined $5,000; Suspended 30 days in all capacities
Kevin Paul O’Brien
AWC/2008015004001
O'Brien engaged in outside business activities for a customer without providing prompt written notice to his member firm. While engaged in the outside business activities for his customer, O’Brien transferred $378,000 between the customer’s accounts, using a portion of the funds to pay the customer’s legitimate expenses and misappropriating the remaining funds for his own use and benefit.
Kevin Paul O’Brien: Barred
October 2009
James Sharpe Stanton
AWC/2008014243301
Stanton engaged in outside business activities without providing prompt written notice to his member firm.
James Sharpe Stanton: Fined $2,500; Suspended 20 business days in all capacities
Chavez failed to disclose to his member firm that he opened and maintained a brokerage account at another firm, and failed to disclose to the other firm that he was a registered representative with a member firm. Chavez made material misrepresentations to his member firm about his outside business activity and made material misrepresentations to both firms regarding his outside securities account. Chavez participated in firm audits and compliance questionnaires and falsely reported that he did not participate in any outside business activities. Chavez engaged in outside business activities without providing notice to his member firm and failed to appear for FINRA on-the-record interviews. 
Miguel Alberto Chavez: Barred
September 2009
Daniel Lee Eppinga
AWC/2007009718801
Eppinga assisted a customer with a purchasing transaction completed outside the scope of his relationship with his member firm, received $6,301.46 in compensation for his role and did not provide his firm with prompt written notice of his outside business activity.  Eppinga failed to appear for a FINRA on-therecord interview.
Daniel Lee Eppinga: Barred
Derek Roy Kent
AWC/2007008911201

Kent 

  • participated in private securities transactions, received compensation for his participation, failed to provide his member firm with prior written notice, and failed to receive the firm’s prior written approval;
  • engaged in outside business activities and failed to provide his firmwith prompt written notice. 
  • negligently failed to advise investors and firm customers of material facts concerning a real estate venture and his involvement; specifically, that proceeds from the venture were to be applied towards defaulted bank loans for which he was personally liable.
Derek Roy Kent: Barred
Joseph Ryan Quinn
AWC/2007009718802
Quinn engaged in an outside business activity, received $5,149.26 in compensation for his role, and did not provide prompt written notice to his member firm. Quinn failed to appear for a FINRA on-the-record interview. 
Joseph Ryan Quinn: Barred
Kenneth Scott Rubin
OS/2007011499201
Rubin participated in private securities transactions, outside the scope of his employment with a member firm, without prior written notice to, and written permission from, his member firm. Rubin misled the firm each year when he completed Outside Business Activities Questionnaires and stated that he had not solicited and did not plan to solicit clients to participate in private securities transactions, had not raised equity for any private ventures and was not involved in real estate sales. 
Kenneth Scott Rubin: Barred

Russo failed to provide written notice to his member firm that he was engaged in outside business activities for compensation. While associated with a member firm, Russo opened an account with another member firm and failed to notify either his member firm or the executing member firm, in writing, of his association with the other firm. 

Ronald Peter Russo Jr. (Principal): Fined $7,500; Suspended 60 days
August 2009
Darrel Gideon Kluge
AWC/2008012186401
Kluge engaged in an outside business activity, for compensation, without prompt written notice to his member firm, and also participated in private securities transactions, for no compensation, and failed to provide his member firm with written notice of the transactions and did not receive the firm’s approval to participate in the transactions. 
Darrel Gideon Kluge: Fined $15,000; Suspended 1 year
Gail Sylvenia Frick
AWC/2008013428001
Frick engaged in outside business activities and private securities transactions without prior written notice to her member firm. Frick was provided a money order by a customer in order to open an account at her member firm on behalf of the customer’s children, misplaced the money order and, in an attempt to settle the customer’s potential complaint in this matter, deposited $1,100 of her own personal funds into an account at her firm for the benefit of the customer’s children without notifying the customer or the firm. Frick used the funds she had previously deposited into the account to purchase mutual funds for the account without the customer’s knowledge, authorization or consent.
Gail Sylvenia Frick: Fined $25,000; Suspended 15 months
Bill Singer's Comment
Talk about the kitchen sink: OBA, PST, Undisclosed settlement, and unauthorized purchase. Frankly, the sanction struck me as a bit generous --- Frick either had a good lawyer or got to FINRA on a good day.

If I have one quibble, it's that I don't think FINRA is on particularly sound ground if it cites an RR for the undisclosed settlement of a complaint if there isn't an actual complaint but merely a "potential" complaint (there we go again with those troublesome adjectives and adverbs). All customers have potential complaints about virtually everything. Likely, Frick "anticipated" that the customer would complain about the misplaced money order, but that's not the same thing as charging her with the undisclosed settlement of an actual complaint. What happened here is that a money order (apparently for $1,100) was lost and rather than ask the customer to provide a replacement, Frick simply went out of her own pocket to cover the funds. No...that doesn't make her actions right but it does put them in a far different light than describing the underlying conduct as settling a customer complaint. We need to be particularly precise when drafting regulatory opinions because they are often used to support sanctions to be imposed in other similar cases.
Hector J. Gallardo
2007010869001
Gallardo engaged in outside business activities without notifying his member firm. Gallardo signed a statement indicating that he had read and agreed to his member firm’s written supervisory procedures that prohibited registered representatives from engaging in any transaction not sponsored or authorized by the firm. Gallardo provided fictitious monthly account statements to clients purporting to be monthly account statements from his unregistered investment company, and failed to respond to FINRA requests for information.
Hector J. Gallardo: Barred; Ordered to pay $984,774, plus interest, in restitution to customers.
Brueggemann participated in private securities transactions without prior written notice to, and prior written approval from, his member firm. Brueggemann failed to provide his member firm with written notice of outside business activities and failed to respond to FINRA requests for information. 
Jan Lynn Brueggemann: Fined $25,000; Suspended 1 year; Barred in all capacities
REDACTED (Principal)
OS/2007007795401

REDACTED electronically affixed two customer names to three solicitor disclosure statements without their specific authority, and created an email that was purportedly received from the customer, which he forwarded along with the false disclosure statements to his member firm for processing. By creating a false disclosure statement,REDACTED caused his member firm to violate the requirements of the Investment Advisors Act of 1940 and, by creating the purported email, REDACTED caused his firm’s records to be inaccurate and thereby prevented it from meeting its obligation to preserve, for a period of not less than six years, the first two years in an accessible place, all records required pursuant to SEC Rule 17a-4(b)(4). 

Also, REDACTED engaged in outside business activities and private securities transactions without written notice to, or approval from, his member firm. REDACTED failed to respond to FINRA requests for documents and information. 

REDACTED (Principal): Barred
Kaeser engaged in an outside business activity and failed to give prompt written notice to his member firm. Kaeser participated in private securities transactions without first providing written notice to his firm.
Roland Karl Kaeser (Principal): Fined $15,000; Suspended 1 year
Waltsak engaged in outside business activities without providing written notice to his member firm, and subsequently failed to respond to a FINRA request for documents and information.
Tyler Anders Waltsak: Barred
July 2009
David Robert Lewandowski
AWC/2007011817201
Lewandowski engaged in outside business activities, and received $442,266.34 in compensation, without prompt written notice to his member firm. Lewandowski falsely asserted on annual certification statements that he was not engaged in any undisclosed outside business activities. 
David Robert Lewandowski: Fined $10,000; Suspended 6 months
Fabian Cesar Seyller
AWC/2007009359601
Seyller engaged in outside business activities, and received $11,925.66 in compensation, without prompt written notice to his member firm. Seyller falsely asserted on an annual certification statement that he was not engaged in any undisclosed outside business activities and did not receive any referral fees. He falsely denied any involvement with equity indexed annuity sales when a supervisor directly questioned him. 
Fabian Cesar Seyller: Fined $5,000; Suspended 6 months
Bill Singer's Comment
As rumored throughout the industry, FINRA seems to be fixated on all sorts of annuities matters -- with a focus on EIAs.
Fabian received $104,000 from an individual for the purchase of real estate. That individual requested documentation of his agreement and Fabian falsified a document to create the appearance that the funds paid to him were invested in real estate, but there was no evidence regarding what Fabian did with the money, although he eventually repaid the individual. Fabian engaged in outside business activities, for compensation, without prior written notice to his member firm. 
Joseph Stephen Fabian (Principal): Barred (based upon his failure to respond to FINRA requests for information)
Paul Anthony Verostko
AWC/2008012540801
Verostko sold fixed annuities to customers without prompt written notice to his member firmof his outside business activities. Verostko could have sold the fixed annuities through his member firm; however, by conducting the transactions away from the firm, he received $100,000 more in commissions than he would have if the annuities had been sold through the firm. Verostko falsely certified to the firm that he was not engaged in any outside business activities.
Paul Anthony Verostko: Fined $10,000; Suspended 18 months
Bill Singer's Comment
This case underscores many issues that raise troubling questions about the theoretical underpinning of the entire stockbroker commission system. First off, how is it...seriously...how is it that there could be a swing of as much as $100,000 on the sale of the same underlying product?  Doesn't that suggest that there are incredible pressures on RRs to push certain product whether suitable or not---house product or otherwise?  

Assuming that an RR's firm and another member firm are in a position to offer the same product and the sale of said product passes the suitability test, then why shouldn't a salesperson be permitted to offer that product through whichever firms is prepared to pay the highest commission?  Truly, I understand and know the legitimate objection but I raise this question somewhat rhetorically.  This temptation should not exist.  It is unhealthy for the industry, for the selling broker, and for the customer.

Robert Michael Bonner
AWC/2007011402701
While registered with member firms, Bonner engaged in outside business activities, for compensation, without prompt written notice to the firms. Bonner completed an Outside Activities Disclosure Form, which one firm required, and did not disclose his outside business activities. Also,  Bonner engaged in private securities transactions, for compensation, without prompt written notice to, and approval from, his member firms. Bonner borrowed $900,000 from firm customers when firm procedures prohibited such borrowing.
Robert Michael Bonner: Barred
Thomas Campbell
AWC/2007011120501
Campbell engaged in outside business activities, for compensation, and failed to notify his firm in writing. Campbell signed firm forms to indicate that he understood his firm’s policies on outside business activities and was not engaged in any such activity
Thomas Campbell: Fined $10,000; Suspended 18 months
Cline engaged in private securities transactions without prior written notice to, or prior approval from, hismember firm. The findings stated that Cline engaged in outside business activities without prompt written notice to his firm. Cline provided false information about his private securities transactions and outside business activities on firm compliance questionnaires. 
William Edward Cline (Principal): Barred
June 2009
Workman engaged in outside business activities for compensation, outside the scope of his relationship with his member firm, and failed to provide prompt written notice to his firm.
Bruce Dudley Workman (Principal): Fined $7,500; Suspended 10 business days
Haas participated in outside business activities without providing his member firm with written notice of these activities. Haas falsified correspondence to cover up these activities and falsely certified to his firm he was not engaged in outside business activities. He failed to appear for a FINRA on-the-record interview
David Christian Haas (Principal): Barred
Galen Mark Shoff
AWC/2008015323501
Shoff sold equity-indexed annuities for compensation outside the scope of his employment with a member firm without providing the firm prompt written notice of the business activity. 
Galen Mark Shoff: Fined $5,000; Suspended 3 months
McFarlane sold equity indexed annuities, for compensation, outside the scope of his employment with his member firm and without providing the firm with prompt written notice of the outside business activity.
John Lloyd McFarlane (Principal): Fined $5,000; Suspended 4 months
Steven Effron
AWC/2007009353701

While Effron was registered with a member firm, he engaged in outside business activities and failed to provide prompt written notice by completing and submitting an Outside Business Activity Notification Form. 

Effron placed variable annuity transactions through his member firm for customers of a representative from another member firm without discussing the transactions with the customers, and after receiving the completed and signed applications, he submitted them to his firm for processing. Effron received commissions from the transactions and forwarded most of the commissions to the representative without advising his firm of the arrangement

Steven Effron: Fined $10,000; Suspended 4 months in all capacities
Terry L. Westlund
AWC/2008012075301
Westlund purchased an interest security in a private offering without providing his member firm with written notification that he engaged in a private security transaction, and did not receive written approval from his member firm. 
Terry L. Westlund: Fined $10,000
Victor Manuel Puig
AWC/2007008178501
Puig engaged in business activities outside the scope of his employment relationship with his member firm, without providing notice to his firm. 
Victor Manuel Puig: Fined $5,000; Suspended 20 business days
Yongsheng Xu
AWC/2007011851801
Xu engaged in outside business activities for compensation, outside the scope of his relationship with his member firm, and failed to provide prompt written notice of this compensation to his firm.
Yongsheng Xu: Fined $5,000; Suspended 30 business days
May 2009
Nathan James Lorne
2006005523401
Lorne made unauthorized withdrawals totaling approximately $12,101 from an organization for which he was treasurer, and hid the withdrawals from the organization’s officers and submitted false financial reports to the organization. Lorne converted the funds for his own personal use, except for a small amount that was for legitimate expense reimbursement, but repaid the organization after he was confronted about the unauthorized withdrawals. He engaged in outside business activities and failed to provide prompt written notice to his member firm, and made misrepresentations to his firm regarding any outside business activity. 
Nathan James Lorne: Barred
Patrick engaged in an outside business activity without prompt written notice to his member firm; conducted private securities transactions without prior written notice to, or prior written approval from, his member firms; and failed to respond to FINRA requests for information and documents.
Richard Vincent Patrick (Principal): Barred
April 2009
Allerton Towne
2005003031001
Towne intentionally, and without authorization, converted $4,181.81 from a customer account to the account of a corporation he owned with the same name, and used the funds for personal expenditures. Towne engaged in outside business activities, for compensation, and failed to notify his member firm.  Towne failed to respond to FINRA requests for documents. 
Allerton Towne: Barred

Sucoff and Mason engaged in outside business activities, for compensation, without providing prompt written notice to their member firm.

Cary William Sucoff (Principal) and Lewis Mason: Fined $10,000 each; Suspended 15 business days

Gary Allen Hanson
AWC/2007010999601
Hanson participated in outside business activities, for commissions and compensation, and failed to provide his firm with prompt written notice. 
Gary Allen Hanson: Suspended 9 months in all capacities
Albertson engaged in outside business activities, for compensation outside the scope of his relationship with his member firm, without providing prompt written notice to his member firm. 
John Wellington Albertson Jr.: Fined $5,000; Suspended 45 business days all capacities.
Mitsuhiro Ide
AWC/2007009360801
Ide engaged in an outside business activity, for compensation, without providing notice to his member firm. Ide provided inaccurate information and made misstatements to his firm relating to his undisclosed outside business activity on annual audit questionnaires and during a firm internal investigation.
Mitsuhiro Ide: Fined $10,000; Suspended 6 months in all capacities
Philip Donato Rossi
2007010767201
Rossi engaged in outside business activities, for compensation, and failed to give prompt written notice to his member firm. He failed to disclose material information on his Form U4 and failed to respond to FINRA requests for information.
Philip Donato Rossi: Barred
Pickle engaged in a private securities transaction and failed to give prior written notice to, or receive written approval from, his member firm. He also engaged in outside business activities, for compensation, without prompt written notice to his member firm. Pickle denied receipt of outside compensation when his member firms pecifically asked him. 
Phillip Alan Pickle (Principal): Fined $10,000; Suspended 9 months in all capacities
March 2009
Jorge Gomez Jr.
2007010995401
Gomez failed to respond to FINRA requests for information, and engaged in outside business activities, for compensation, without providing prompt written notice to his member firm. 
Jorge Gomez Jr.: Barred
Kenneth Lenell Street
AWC/2007010105201
Steet engaged in outside business activities, for commissions, without providing prompt written notice to his member firm. Street was asked on a required firm compliance questionnaire whether he engaged in outside business activities and accepted commissions from sources other than his member firm, he incorrectly answered “no.” 
Kenneth Lenell Street: Fined $5,000; Suspended 6 months
Ventresca engaged in outside business activities, for compensation, and failed to provide prompt written notice to his member firm on annual outside business activity forms or in any other written form.
Lawrence Louis Herman Ventresca: Fined $10,000; Suspended 3 months
February 2009
Brian Robert Nord
AWC/2007007609901
Nord loaned to or borrowed from firm customers amounts ranging from $4,000 to $500,000, sometimes on more than one occasion, without his member firm’s written approval in accordance with the firm’s written procedures. Nord engaged in an outside business activity, for compensation, without prompt notice, written or otherwise, to his member firm, and failed to respond to a FINRA request to appear for an on-the-record interview. 
Brian Robert Nord: Barred
Daniel Joseph Roberts
AWC/2007008016201
Roberts borrowed $10,000 from a public customer without written approval in accordance with his firm’s written procedures, and engaged in an outside business activity with the expectation of compensation without prompt notice, written or otherwise, to his member firm. 
Daniel Joseph Roberts: Fined $10,000; Suspended 100 days in all capacities
Eric Andy Fiszer
AWC/2007010577101
Fiszer engaged in outside business activities, for compensation, and failed to give prompt written notice to his member firm.
Eric Andy Fiszer: No fine in light of financial status; Suspended 30 days in all capacities
James Stanley Gossett
AWC/2007008653501

Gossett made unsuitable investment recommendations to public customers, in that they were inconsistent with each customer’s financial situation, investment objective, circumstances and needs. In verbal and written communications with customers, Gossett made misleading or unwarranted claims about his investment strategy, particularly regarding investment risks, and made predictions or projections of the future performance of the strategy without providing a sound basis for evaluating his assertions. Gossett prepared and distributed to prospective customers sales literature about his investment strategy that failed to include risk disclosures and provided misleading information about past performance; provided incomplete and/or misleading information to customers about the performance of their investments and/or the account balance; and prepared an account statement for a customer in which he did not report all of the customer’s account holdings and thus reported an account balance that was greater than actual. 

Gossett exercised discretion in firm customer accounts without the customers’ prior written authorization and his member firm’s prior written acceptance. Gossett enlisted the service of a non-registered individual to solicit investors to open accounts with Gossett, promote Gossett’s investment strategy, assist customers with completing application forms and serve as Gossett’s primary point of contact. As compensation for the services, Gossett agreed to pay the individual half of the commissions he generated from trades in the customers’ accounts

In addition, Gossett opened a securities brokerage account with another FINRA member without providing written notice to his member firm and without advising the other firm of his association with a member firm; failed to disclose the account to his member firm after he opened the account; and failed to provide written notice to his member firm that he was engaged in an outside business activity. In response to a request for information, Gossett knowingly provided false and misleading information. 

James Stanley Gossett: Barred
Bill Singer's Comment
Awesome!!!  Just re-print this case and send it around the office. It's a blueprint of nearly everything NOT to do. If this were a pinball game, we would have hit all the bumpers, gotten all the bonuses, and won a free ball at the end -- except, this isn't a game and, in the end, Gossett got barred. Not much of a prize.
Jeffery David Hunt
AWC/2007008946401
Hunt failed to disclose an outside business activity to his member firm; and failed to respond to FINRA requests for information. 
Jeffery David Hunt: Barred
Tamra Renee Morriston
OS/2007010598501
Mooriston engaged in outside business activities without her member firm’s prior written notice; andfailed to comply with FINRA requests for information and documents, and failed to appear for a FINRA on-the-record interview. 
Tamra Renee Morriston: Barred
Lochtefeld engaged in outside business activities, for compensation, and failed to give prompt written notice to his member firm. 
Vernon A. Lochtefeld (Principal): Fined $5,000; Suspended 30 days in all capacities
Yvonne Yuliene Russell
AWC/2007010844301
Russell loaned $150,830 to a firm customer, but her member firm had policies prohibiting this activity, and she neither had permission to loan the funds, nor did she make her firm aware of the loans to the customer. Also, Russell engaged in an outside business activity, for compensation, without providing verbal or prompt written notice to her firm. 
Yvonne Yuliene Russell: Fined $10,000; Suspended 30 business days in all capacities
January 2009
Fishman willfully failed to disclose material information on his Form U4 and his member firm’s annual compliance forms. Also, he engaged in an outside business activity, for compensation, and failed to provide prompt written notice to his member firm.
Avidan Danny Fishman (Principal): Fined $2,500; Suspended 6 months in all capacities (willful failure to disclose) and 1 month in all capacities (outside business activity)
David Randall Paul
AWC/2007011115801
Paul engaged in outside business activities without prompt written notice to his member firm.
David Randall Paul: Fined $5,000; Suspended 30 days in all capacities
Tipton engaged in an outside business activity, for compensation, without prompt written notice to his member firm. Also, he loaned $600 to a public customer in breach of his firm’s procedures that prohibited borrowing and lending transactions with customers. Tipton failed to appear for a FINRA on-the-record interview. 
Jeffrey Eugene Tipton: Barred
Jeffrey Michael Stebbins
OS/2006004969703

Stebbins engaged in his member firm’s investment banking and securities business in capacities requiring registration as a representative and principal, but he was not registered in those capacities. Stebbins engaged in an outside business activity, for compensation, without prior written notice to his member firm. Stebbins had a beneficial interest in securities accounts maintained at other member firms and failed to disclose to the carrying broker-dealers that he was associated with FINRAmembers, and also failed to give his member firms written notification that he had a financial interest in securities accounts with the carrying broker-dealers. 

Stebbins knowingly provided false and/or misleading information in response to FINRA requests for information; and failed to respond to FINRA requests to appear for an on-the-record interview and to provide information and documents. 

Jeffrey Michael Stebbins: Barred
John Keith Kutsche
2006006913501
Kutsche engaged in outside business activities without prompt written notice to his member firm, and failed to respond to FINRA requests for information and to appear for an on-the-record interview.
John Keith Kutsche: Barred
Noah James Aulwes
AWC/2007009254101
Aulwes engaged in outside business activity, for compensation, without prompt written notice to his member firm. Aulwes participated in private securities transactions without prior written notice to, and written approval or acknowledgement from, his member firm. 
Noah James Aulwes: Fined $10,000; Suspended 1 year in all capacities
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