Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2011
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.
June 2011
Montford Sater Will (Principal)
AWC/2009018334601/June 2011
Will made a series of political campaign contributions to various candidates and parties, donating a total of approximately $121,000 to campaigns in his relativesí names.These campaigns included local, county and municipal races, statewide races and state political parties. Will admitted that by making the political contributions in his relativesí names, he violated Ohio Revised Code Section 3517.13(G)(2)(a), which prohibits a person from making a campaign contribution in another personís name.
Montford Sater Will (Principal): Fined $10,000; Suspended 60 days. After consideration of the sanctions the State of Ohio previously imposed on Will, FINRA determined to give him credit for the amount he paid the state and the 45-day suspension he previously served. Accordingly, the $10,000 fine and 45 days of the suspension assessed were deemed to have been fulfilled.
Tags:  Campaign Contributions     |    In: Cases of Note : FINRA
Bill Singer's Comment
Practice pointer: Note that you can ask for credit for time served and/or dollars paid to one regulator when negotiating sanctions with another regulator concerning similar facts. Moreover, it may even be smart to try and "arbitrage" the fines/suspensions in the event that you might wish to serve your time sooner rather than later (i.e., you know that the second regulator may impose a suspension that would be served during a busy season).
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