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.
Ramius Securities LLC
AWC/2007010580701/April 2010
The Firm lacked supervisory systems and written procedures reasonably designed to prevent and detect improper use of, and payment to, finders used in stock loan transactions. The Firm failed to download instant messages and emails the firm’s employees sent or received via Bloomberg into its internal systems; therefore, the firm did not archive them.
Ramius Securities LLC: Censured; Fined $200,000
Richard Louis Galterio (Principal)
AWC/2008011736102/February 2010
Acting through Galterio, his firm failed to retain all business-related electronic communications. Galterio used and permitted at least one of the firm’s registered representatives to use an electronic instant messaging service in conducting the firm’s business, although the firm did not maintain and preserve instant messaging communications.
Richard Louis Galterio (Principal): Fined $5,000; Suspended 45 business days in Principal capacity only