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.

James Richard Thomas (Principal)
AWC/2008014538301

Thomas participated in private securities transactions and received compensation, but failed to provide prior written notification to, and receive prior written permission from, the firm to participate in the private securities transactions. Thomas failed to disclose these private securities transactions when he completed the firm’s annual compliance check list. Subsequently, Thomas provided an incomplete response to a FINRA request for information, and failed to respond to subsequent requests for information and documents. 

James Richard Thomas (Principal): Barred