• approved registered representatives’ participation away from the firm in raising capital for a company by selling its stock, but imposed conditions on their participation and required that the stock certificates not bear restrictive legends;
• failed to take reasonable steps to monitor or determine compliance with these conditions, including conducting an inquiry of “red flags” that suggested violations of federal securities laws; and
  
• Fischer failed to detect and prevent the representatives’ distribution of unregistered securities in their capacity as underwriters.
  

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.

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. 

Weaver and Will participated in private securities transactions, for compensation, in the sale of securities issued by another firm and did not provide prior written notice to, or receive prior approval from, their member firm. They incorrectly answered “no”when asked on required annual compliance questionnaires whether they had ever been paid or received a referral or finder’s fee from anyone for referring securities clients and/or business. 

Randy Brian Weaver: No fine in light of financial status; Suspended 9 months

Richard Lance Will: No fine in light of financial status; Suspended 8 months

Acting through Dash, Hallmark 

• filed a membership application that was incomplete or inaccurate so as to be misleading, and failed to correct the filing, and T
• failed to file a required application with FINRA for approval of change of ownership. 

Dash engaged in private securities transactions without providing prior written notice to his member firms or securing the firms’ written approval. 

Hallmark Investments, Inc.: Censured; Fined $15,000

Steven Gary Dash (Principal) No Fine in light of financial status; Suspended 2 months in all capacities

permission from, her member firm.