NOTE: 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 and to the entry of findings.

Playing Musical Chairs:
The Pitfalls of Using Another's Registration 

by Bill Singer bsinger@rrbdlaw.com

Steven Phillip Charron (AWC/C11030008/May 2003)
Registered Principal Charron recommended and initiated unsuitable transactions for public customers. Also, in order to circumvent the denial of his registration status in Rhode Island, Charron arranged for another Rhode Island registered person to be falsely reflected as handling the account (despite the fact that the account was controlled and actively traded by Charron). Charron also received the commissions on the transactions at issue.
Barred in all capacities

Lee Matthew Solomon, Jr., (C10020083/March 2003)
Solomon allowed his member firm to put his production number on another RR's accounts, notwithstanding that the latter individual was under enhanced supervision. Said conduct furthered a scheme that allowed the RR to continue to execute transactions in the accounts under Solomon's number and created the false impression that the RR was in compliance with the enhanced supervision.
Fined $30,000; Suspended 1 year in all capacities; Must requalify before re-entry

Marlon Francisco Delgado (AWC/C10020093/NOVEMBER 2002)
RR Delgado Delgado solicited public customers to purchase securities, downplayed the attendant investment risks, and made unwarranted price predictions, causing the customers to authorize and pay for the transactions. He also effected transactions in the account of a public customer without the customer’s prior knowledge, authorization, or consent. Finally, he effected the sale of securities in at least three states in which he was not yet registered, and attempted to conceal it by placing the trades under another broker’s name.   
Fined $10,000;suspended in all capacities for 18 months;
required to requalify by examination as a general securities representative before associating with any NASD member in any capacity.