SFC/ 08-047
Between January 2003 and March 2004 (the “relevant period”), while employed at Baseline Securities Inc. and LaBranche Financial Services, Inc. (“LFSI”), institutional sales representative Cronin engaged in an undisclosed outside business and profit- sharing arrangement with a third party, whereby Cronin would refer customers to the third party for NASDAQ trading in exchange for 50 percent of the after expense profits. During the relevant period, Cronin received monthly payments of between $60,000 and $100,000. Cronin never made a written request or received the prior written approval of LSFI to engage in this profit-sharing arrangement. When the profit-sharing arrangement ended, Cronin received a payment of $950,000 as compensation for lost profits. Subsequently, in connection with an NYSE Enforcement investigation, Cronin was asked to provide testimony concerning his outside business activities. Cronin made material misstatements in testimony to NYSE Enforcement about the profit-sharing arrangement and about the $950,000 he received. Further, in October 2004 Cronin made misstatements to his member firm employer, LFSI, on a questionnaire concerning his business relationship with another individual.
Violated NYSE Rule
- 346(b) by engaging in outside business activity by entering into profit-sharing arrangement with third party without making written request and receiving prior written consent of member organization employer;
- 476(a)(4) by making material misstatements to NYSE;
- 476(a)(6) by engaging in outside business without approval of member organization employer, making material misstatements to Exchange and making material misstatements to member organization employer about business relationship.
- 529 College Savings Plan
- AML
- Annual Compliance Certification
- Annuity
- ATM
- Away Accounts
- Bank
- Blank Forms
- Borrowing
- Broadcast
- Changes Of Address
- Checks
- CIP
- Class B Shares
- Clearing Agreement
- Communications
- Cooperation Agreement
- Corporate Credit Card
- Debit Card
- Deceased
- Disabled
- Discretion
- Elderly
- Electronic Communications
- Escrow
- Expenses
- False Professional Designation
- False Statements
- FOCUS
- Forgery
- Gifts
- Guaranteeing Against Losses
- Heightened Supervision
- Inaccurate Information To FINRA
- Increase The Number Of RRs
- Instant Messaging
- Internet
- Joint Account
- JWillfully
- Markdowns
- Markups
- Membership Agreement
- Minimum Contingency
- Mispricing
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- No Objections Letter
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