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.

Thomas R. Gilman
2008013474801

Gilman participated in private securities transactions involving the purchase by his member firm’s customer of convertible debentures another company offered, and these transactions were outside the regular course and scope of Gilman’s employment with the firm. Gilman first received a $50,000 finder’s fee and failed to provide the firm with prior written notice or receive the firm’s written permission. Gilman completed and submitted firm compliance questionnaires and, in response to the question concerning whether he sold any products or services not marketed through his firm, he answered “no” and provided incomplete information to his branch manager in response to an inquiry about activities in the customer’s account.

Thomas R. Gilman: Fined $60,000; Suspended 15 months