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 William Hands (Principal)
OS/2009016158501

Hands submitted inaccurate attestations to FINRA certifying that, among other things, his member firm’s compensation committee had reviewed and approved each research analyst’s compensation and documented the basis upon which the compensation was established. Hands understood the importance of an accurate attestation because he submitted an inaccurate one after he was aware that FINRA was investigating whether a firm research analyst’s activities violated

Thomas William Hands (Principal): Fined $10,000; Suspended 15 business days