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.

Joseph John Giuliano (Principal)
AWC/2009019382101

An individual who subsequently became a trader with Giuliano's member firm provided $250,000 to the firm’s parent company, without loan documentation or written agreement, either as funds to be traded in a firm proprietary account or be held as a security deposit to insure the brokerdealer against trading losses the individual might incur. Giuliano, an owner of at least a 40-percent stake in the parent company and the firm’s chief financial officer (CFO) and FINOP, caused the funds to be deposited into the parent company’s checking account and used some or all of the funds, without the individual’s consent or authorization, to pay various expenses and debts of the parent company and the firm, thereby misusing the funds.

Joseph John Giuliano (Principal): Barred

Tags: Proprietary Traders  Loan  FINOP