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.

Max Sean Nelson
AWC/2008015220001

Nelson participated in private securities transactions involving the purchasing of commercial and residential rental properties, through investing and loaning of investors’ funds in companies he controlled without prior written notice to, or written approval from, his member firm. Nelson completed his member firm’s compliance questionnaires and, in response to the question, “I have only offered for sale securities and non-securities investments, which at such time were authorized by the firm in writing,” Nelson falsely answered “Yes.”

Max Sean Nelson: Fined $5,000; In light of Nelson’s restitution being ordered pursuant to a 2009 agreement entered into with the Missouri Attorney General, no restitution sanction was imposed; Suspended 1 year