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.
Alan David Goddard Jr.
AWC/2009016157802
Goddard actively engaged in a member firm’s investment banking and
securities business
as a principal without proper registration.
Goddard signed selling
agreements and consulting agreements with issuers on the firm’s
behalf as an officer of
the firm and worked closely with the firm’s outside counsel to
establish the terms of selling
agreements and private placement offerings that the firm
conducted. Unbeknownst to
Goddard, the firm’s CCO amended the firm’s Application for
Broker-Dealer Registration
(Form BD) to list Goddard as the firm’s CEO.
During
Goddard’s entire association with the firm, he was only registered
as a general securities
representative; Goddard took the Series 24 examination but failed.
Goddard erroneously
believed that he could function in the capacities set forth above
without a principal’s
license.
Alan David Goddard Jr.: Fined $10,000; Suspended 45 days