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Microcap & Penny Stocks : Zia Sun(zsun)

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From: StockDung8/17/2005 8:01:46 PM
   of 10354
 
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

********************************************************************************
REGULATORY ACTIONS
********************************************************************************
DISCLOSURE INFORMATION


This section lists regulatory actions that were reported to CRD and are
disclosable through NASD BrokerCheck. Disclosable regulatory actions include
formal proceedings initiated by a regulatory authority (i.e., a state
securities agency, NASD, New York Stock Exchange, foreign regulatory body,
etc.) for a violation of investment-related rules or regulations. In addition,
revocations or suspensions of an individual broker's authority to act as an
attorney, accountant or federal contractor will appear here.

Some of the fields in this section of the report may be blank if the information
was not provided to CRD.


** OCCURRENCE COUNTS ** 5 Record(s)

********************************************************************************

** FIELD DEFINITIONS **

* Reporting Source: The form through which details of the regulatory
action was reported to CRD.

* Date Reported: The date the regulatory action was reported to
CRD.

* Initiated By: The name of the securities regulator that
initiated the regulatory action (e.g.,
regulator, foreign financial regulatory
authority, self-regulatory organization, federal
agency such as SEC, state, etc.).

* Date Initiated: Date the regulatory action was initiated.

* Docket/Case Number: Docket or case number of the regulatory action.

* Employing Brokerage Firm: Brokerage Firm where individual broker was
employed when activity occurred that led to the
regulatory action.

* Allegations: Allegations made against the individual broker
leading to the regulatory action.

* Current Status: The current status of the regulatory action
(i.e., pending, on appeal or final).

* Resolution: The resolution of the regulatory action (e.g.,
acceptance, waiver and consent; decision;
decision and order of offer of settlement;
order; settled; etc.).

* Resolution Date: The date the regulatory action was resolved.

* Sanction Details: Additional details regarding any sanctions
ordered.

* Summary: A summary of the details related to the
regulatory action.

********************************************************************************


******** REGULATORY ACTION (1 of 5) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 05/17/2004

Initiated By: NASD

Date initiated: 12/04/2003

Docket/
Case Number: CAF030063

Employing Brokerage Firm: DIRKS & COMPANY, INC.

Allegations: NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B),
2210(D)(2)(B)(I), 2210(D)(2)(B)(I)(A), 2210(D)(2)(C), 2711 - A
MEMBER FIRM, ACTING THROUGH RAY DIRKS, FAILED TO DEFINE THE
MEANING OF EACH RATING USED IN THE FIRM'S RATING SYSTEM IN
RESEARCH REPORTS; ACTING THROUGH RAY DIRKS, FAILED TO DISCLOSE
THE VALUATION METHOD USED TO DETERMINE A PRICE TARGET, PROVIDE
A REASONABLE BASIS FOR PRICE TARGETS, AND INCLUDE A DISCLOSURE
CONCERNING THE RISKS THAT MAY IMPEDE THE ACHIVEMENT OF THE
PRICE TARGET IN REPORTS; A MEMBER FIRM, ACTING THROUGH DIRKS,
FAILED TO DISCLOSE THAT IT IS A MARKET MAKER IN A PARTICULAR

NASD BrokerCheck August 17, 2005 Page 5
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

REGULATORY ACTIONS(cont.)

SECURITIES AT THE TIME THE SECURITIES RESEARCH REPORT WAS
PUBLISHED; A MEMBER FIRM, ACTING THROUGH DIRKS, FAILED TO MAKE
CERTAIN DISCLOSURES AS REQUIRED BY NASD RULE 2210; A MEMBER
FIRM, ACTING THROUGH DIRKS, OMITTED MATERIAL FACTS WHICH
CAUSED RESEARCH REPORTS TO BE MISLEADING, REPORTED PRICE
TARGET PROJECTIONSS AND REVENUE ESTIMATES THAT WERE
EXAGGERATED, UNWARRANTED, MISLEADING, WITHOUT A LEGITIMATE
BASIS, AND FORECASTS OF FUTURE EVENTS THAT WERE UNWARRANTED.

Current Status: Final

Resolution: Decision & Order of Offer of Settlement

Resolution Date: 04/27/2004

Sanctions
Ordered: Monetary/Fine, Suspension

Monetary Amount: $25,000.00

Resolution
Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DIRKS CONSENTED
TO THE DESCRIBED SNACTIONS AND TO THE ENTRY OF FINDINGS,
THEREFORE, HE IS FINED $25,000 AND SUSPENDED FROM ASSOCIATION
WITH ANY NASD MEMBER IN ANY CAPACITY FOR 30 DAYS. SUSPENSION
EFFECTIVE MAY 17, 2004 TO CLOSE OF BUSINESS JUNE 15, 2004.

Summary:


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 06/17/2004

Initiated By: NASD OFFICE OF HEARING OFFICERS

Date initiated: 12/04/2003

Docket/
Case Number: CAF-030063

Employing Brokerage Firm: DIRKS AND COMPANY, INC.

Allegations: COMPLAINT ALLEGES RAY DIRKS FAILED TO COMPLY WITH PROVISIONS OF
NASD RULES 2711, 2110, AND 2210 REGARDING RESEARCH REPORTS
DIRKS AUTHORED OR CO-AUTHORED.

Current Status: Final

Resolution: Decision & Order of Offer of Settlement

Resolution Date: 04/27/2004

Sanctions
Ordered: Monetary/Fine, Suspension

Monetary Amount: $25,000.00

Resolution
Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DIRKS CONSENTED
TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,
THEREFORE, HE IS FINED $25,000 AND SUSPENDED FROM ASSOCIATION
WITH ANY NASD MEMBER IN ANY CAPACITY FOR 30 DAYS. SUSPENSION
EFFECTIVE MAY 17, 2004 TO CLOSE OF BUSINESS JUNE 15, 2004.

Summary:



******** REGULATORY ACTION (2 of 5) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 09/22/2003

Initiated By: NASD

Date initiated: 08/05/2003

Docket/
Case Number: ARB020032/97-02920

Employing Brokerage Firm:

Allegations: FAILED TO COMPLY WITH A SETTLEMENT AGREEMENT IN VIOLATION OF
RULE 10330(H)

Current Status: Final

NASD BrokerCheck August 17, 2005 Page 6
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

REGULATORY ACTIONS(cont.)


Resolution: Decision

Resolution Date: 08/05/2003

Sanctions
Ordered: Suspension

Other Sanctions: COSTS-$1,689.44

Resolution
Details: PURSUANT TO ARTICLE VI, SECTION 3 OF THE NASD BY-LAWS AND RULE
9514(G), DIRKS' REGISTRATION IS SUSPENDED EFFECTIVE AUGUST 5,
2003. SUCH SUSPENSION SHALL CONTINUE UNTIL HE SHOWS (1) HE HAS
MADE FULL PAYMENT UNDER THE SETTLEMENT AGREEMENT; OR (2) THE
SETTLEMENT AGREEMENT AND JUDGMENT HAVE BEEN MODIFIED; OR (3)
HE HAS FILED A BANKRUPTCY PETITION IN A U.S. BANKRUPTCY COURT
OR THAT THE AWARD HAS BEEN DISCHARGED BY A U.S. BANKRUPTCY
COURT. APPEALED TO THE SEC AND REQUESTED A STAY ON AUGUST 6,
2003. NASD REGISTRATION REINSTATED SEPTEMBER 3, 2003. DIRKS
AND CLAIMANT SETTLED THE AWARD AND DIRKS HAS PAID CLAIMANT THE
SETTLEMENT AMOUNT, SATISFYING THE CONDITIONS NECESSARY FOR
REINSTATEMENT.

Summary:


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/12/2003

Initiated By: NASD

Date initiated: 08/05/2003

Docket/
Case Number: ARB020032/97-02920

Employing Brokerage Firm: COLEMAN & CO

Allegations: FAILED TO COMPLY WITH A SETTLEMENT AGREEMENT IN CONNECTION WITH
A SETTLEMENT AGREEMENT IN VIOLATION OF RULE 10330(H)

Current Status: Final

Resolution: Decision

Resolution Date: 08/05/2003

Sanctions
Ordered: Suspension

Other Sanctions: COSTS-$1,689.44

Resolution
Details: PURSUANT TO ARTICLE VI, SECTION 3 OF THE NASD BY-LAWS AND RULE
9514(G), DIRKS' REGISTRATION IS SUSPENDED EFFECTIVE AUGUST 5,
2003. SUCH SUSPENSION SHALL CONTINUE UNTIL HE SHOWS (1) HE HAS
MADE FULL PAYMENT UNDER THE SETTLEMENT AGREEMENT; OR (2) THE
SETTLEMENT AGREEMENT AND JUDGMENT HAVE BEEN MODIFIED; OR (3)
HE HAS FILED A BANKRUPTCY PETITION IN A U.S. BANKRUPTCY COURT
OR THAT THE AWARD HAS BEEN DISCHARGED BY A U.S. BANKRUPTCY
COURT. APPEALED TO THE SEC AND REQUESTED A STAY ON AUGUST 6,
2003.

Summary: DUE TO MR. DIRK'S CURRENT SUSPENSION, THIS U4 AMENDEMENT WAS
FILED BY THE FIRM(SKY CAPITAL LLC).



******** REGULATORY ACTION (3 of 5) ********


Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/16/2002

Initiated By: NEW YORK STOCK EXCHANGE INC.

Date initiated: 01/01/1967

Docket/
Case Number: UNKNOWN

Employing Brokerage Firm: G.A. SAXTON INC.

Allegations: THE NYSE ALLEGED THAT I PURCHASED AND SOLD SECURITIES WITHOUT
THE USE OF A MEMBER ORGANIZATION.


NASD BrokerCheck August 17, 2005 Page 7
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

REGULATORY ACTIONS(cont.)

Current Status: Final

Resolution: Decision

Resolution Date: 01/01/1967

Sanctions
Ordered: Censure

Resolution
Details: RECEIVED PENALTY OF CENSURE

Summary: DOCUMENTATION NOT AVAILABLE



******** REGULATORY ACTION (4 of 5) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 04/02/2002

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date initiated: 08/25/1976

Docket/
Case Number: ND 76-166, ND 78-173 AND ND 81-16

Employing Brokerage Firm: DELAFTELD CHILDS, INC.

Allegations: SEC ADMINISTRATIVE PROCEEDING CASE NO. ND 76-166, RELESE NO.
34-12733, DATED AUGUST 25, 1976: THE SEC ISSUED AN ORDER TO
FILE A PUBLIC ADMINISTRATIVE PROCEEDING AGAINST RAYMOND DIRKS
("DIRKS"). THE SEC ALLEGED THAT RESPONDENT DIRKS WAS ENGAGED
IN AIDING AND ABETTING OTHERS IN TRADING ON THE BASIS OF
MATERIAL INSIDE INFORMATION IN VIOLATION OF THE ANTIFRAUD
PROVISIONS OF THE SECURITIES LAWS. THE SEC FURTHER ALLEGED
THAT RESPONDENT DIRKS RECEIVED INFORMATION FROM EQUITY FUNDING
INSIDERS CONCERNING FRAUD WITHIN THE COMPANY AND THAT DIRKS
TIPPED THE INFORMATION TO CERTAIN INVESTORS, WHO SOLD THEIR
STOCK, PRIOR TO THE KNOWLEDGE BECOMING PUBLIC.

Current Status: Final

Resolution: Order

Resolution Date: 03/29/1982

Sanctions
Ordered: Censure

Resolution
Details: SEC ADMINISTRATIVE PROCEEDING CASE NO. ND 81-16, RELEASE NO.
34-17480, DATED JANUARY 26, 1981: SEC CENSURED RESPONDENT ON
JANUARY 26, 1981. * SEC NEWS DIGEST ISSUE NO. 82-78, DATED
APRIL 23, 1982: ON MARCH 29, 1982, THE COURT OF APPEALS FOR
THE DISTRICT OF COLUMBIA CIRCUIT AFFIRMED THE SEC'S CENSURE OF
DIRKS FOR AIDING AND ABETTING OTHERS IN TRADING ON THE BASIS
OF MATERIAL INSIDE INFORMATION IN VIOLATION OF THE ANTIFRAUD
PROVISIONS OF THE SECURITIES LAWS.

Summary: SEC ADMINISTRATIVE PROCEEDING CASE NO. ND 78-173, DATED
SEPTEMBER 6, 1978: INITIAL DECISION ISSUED AGAINST RESPONDENT
SUSPENDING HIM FROM ASSOCIATION WITH A BROKER/DEALER FOR 60
DAYS. * THE SEC'S CENSURE WAS BASED ON FINDINGS THAT
RESPONDENT DIRKS RECEIVED INFORMATION FROM EQUITY FUNDING
INSIDERS CONCERNING FRAUD WITHIN THE COMPANY AND THAT DIRKS
TIPPED THE INFORMATION TO CERTAIN INVESTORS, WHO SOLD THEIR
STOCK, PRIOR TO THE KNOWLEDGE BECOMING PUBLIC. IN ITS
JUDGEMENT, THE COURT OF APPEALS STATED THAT THERE WAS NO NEED
FOR AN OPINION SINCE THE SEC DECISION WAS SOLIDLY BASED IN
FACT AND LAW.


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/16/2002

Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION

Date initiated: 08/25/1976

Docket/
Case Number: UNKNOWN

Employing Brokerage Firm: DELAFIELD CHILDS, INC.


NASD BrokerCheck August 17, 2005 Page 8
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

REGULATORY ACTIONS(cont.)

Allegations: SEC ALLEGED THAT I VIOLATED ANTIFRAUD PROVISIONS FOR RECEIVING
INFORMATION CONCERNING FRAUD WITHIN A COMPANY & PROVIDING THAT
INFORMATION TO CERTAIN INVESTORS WHO SOLD THEIR STOCK BEFORE
THE INFORMATION BECAME PUBLICLY AVAILABLE.

Current Status: Final

Resolution: Decision

Resolution Date: 01/22/1981

Sanctions
Ordered: Censure

Resolution
Details: THE SEC UPHELD PENALTY OF CENSURE BUT REJECTED 6 MONTH
SUSPENSION IMPOSED BY ADMINISTRATIVE LAW JUDGE, 9-6-78.
CENSURE WAS OVERTURNED BY THE U.S. SUPREME COURT, 463 U.S. 646
(JULY 1, 1983).

Summary: THE SEC UPHELD PENALTY OF CENSURE BUT REJECTED 6 MONTH
SUSPENSION IMPOSED BY ADMINISTRATIVE LAW JUDGE, 9-6-78.
CENSURE WAS OVERTURNED BY THE U.S. SUPREME COURT, 463 U.S. 646
(JULY 1, 1983).



******** REGULATORY ACTION (5 of 5) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 04/02/2002

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date initiated: 10/13/1982

Docket/
Case Number:

Employing Brokerage Firm: JOHN MUIR & CO.

Allegations: SEC NEWS DIGEST ISSUE NO. 82-197, AND RELEASE NO. 34-19102,
DATED OCTOBER 13, 1982: ADMINISTRATIVE PROCEEDINGS FILED
AGAINST RAYMOND L. DIRKS ALLEGING VIOLATIONS OF THE SECURITIES
LAWS IN CONNECTION WITH A COMPANY'S USE OF THE MAILS AND MEANS
AND INSTRUMENTALITIES OF INTERSTATE COMMERCE TO EFFECT
SECURITIES TRANSACTIONS WHILE FAILING TO COMPLY WITH
BROKER-DEALER NET CAPITAL PROVISIONS OF THE EXCHANGE ACT.

Current Status: Final

Resolution: Order

Resolution Date: 01/12/1987

Sanctions
Ordered: Suspension

Resolution
Details: ADMINISTRATIVE LAW JUDGE ISSUED AN INITIAL DECISION WHICH
BARRED RAYMOND DIRKS FROM ASSOCIATION WITH ANY BROKER-DEALER
IN A SUPERVISORY, MANAGERIAL, FINANCIAL PRINCIPAL OR
PROPRIETARY CAPACITY. * SEC NEW DIGEST ISSUE NO. 85-136, DATED
JULY 16, 1985: THE SEC HAD CHANGED THE SANCTION IN WHICH
RAYMOND L. DIRKS WAS SUSPENDED FROM ASSOCIATION WITH ANY
BROKER OR DEALER IN A PROPRIETARY OR SUPERVISORY CAPACITY FOR
A PERIOD OF SIX MONTHS. * LITIGATIONS ACTIONS AND PROCEEDINGS
BULLETIN, VOLUME 53, BULLETIN 1, PAGE 12 DISCLOSES: ON JULY 5,
1986, THE SIX-MONTH SUSPENSION WAS STAYED PENDING DIRKS'
APPEAL TO THE USCA OF COLORADO CIRCUIT COURT. * SEC NEWS
DIGEST ISSUE NO. 87-4, DATED JANUARY 7, 1987: THE COURT OF
APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT AFFIRMED THE
SEC'S ORDER. THE ORDER OF SUSPENSION IS EFFECTIVE AT BUSINESS
OPENING ON JANUARY 12, 1987.

Summary: SEC FOUND THAT RESPONDENT DERELICT IN FULFILLING MANAGERIAL
RESPONSIBILITIES AND SHARED RESPONSIBILITY FOR COMPANY'S
FINANCIAL COLLAPSE THAT LED TO THE APPOINTMENT OF A SIPC
TRUSTEE TO LIQUIDATE THE FIRM IN AUGUST 1981. THE SEC FOUND
THAT, AFTER HAVING BEEN WARNED OF THE COMPANY'S SEVERE CASH
FLOW PROBLEM, DIRKS FAILED TO FULFILL HIS DUTY TO MONITOR THE
COMPANY'S SITUATION CLOSELY AND TAKE OR DEMAND NECESSARY
ACTION TO AVERT COMPANY'S FINANCIAL COLLAPSE. (REL. SIPC-132).


***********************************
Reporting Source: Individual Broker (Form U-4)


NASD BrokerCheck August 17, 2005 Page 9
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

REGULATORY ACTIONS(cont.)

Date Reported: 08/16/2002

Initiated By: U.S. SECURITIES AND EXCHANGE COMMSSION

Date initiated: 10/04/1982

Docket/
Case Number: 26 SEC DOCKET 372, 33 SEC DOCKET 907

Employing Brokerage Firm: JOHN MUIR & CO

Allegations: THE SEC ALLEGED THAT I AND ANOTHER PARTNER WERE RESPONSIBLE FOR
THE FINANCIAL DEMISE AND SIPC LIQUIDATION OF JOHN MUIR & CO.
AND THAT WE AIDED AND ABETTED THE FIRM'S NET CAPITAL
VIOLATIONS.

Current Status: Final

Resolution: Decision

Resolution Date: 10/10/1986

Sanctions
Ordered: Suspension

Resolution
Details: THE SEC ADMINISTRATIVE LAW JUDGE AFFIRMED THE SEC'S ALLEGATIONS
AND BARRED ME FROM ASSOCIATION WITH ANY BROKER OR DEALER IN A
SUPERVISORY OR PROPRIETARY CAPACITY. ON APPEAL, THE SEC
DISMISSED THE FINDING OF AIDING AND ABETTING NET CAPITAL
VIOLATIONS AND REDUCED THE PENALTY TO A 6 MONTH SUSPENSION IN
A SUPERVISORY OR PROPRIETARY CAPACITY. PENALTY WAS BASED ON
MY ROLE IN MUIR'S FINANCIAL COLLAPSE. THE SEC ORDER WAS
AFFIRMED BY THE U.S. COURT OF APPEALS FOR THE D.C. CIR. IN
OCTOBER 1986.

Summary: THE SEC ADMINISTRATIVE LAW JUDGE AFFIRMED THE SEC'S ALLEGATIONS
AND BARRED ME FROM ASSOCIATION WITH ANY BROKER OR DEALER IN A
SUPERVISORY OR PROPRIETARY CAPACITY. ON APPEAL, THE SEC
DISMISSED THE FINDING OF AIDING AND ABETTING NET CAPITAL
VIOLATIONS AND REDUCED THE PENALTY TO A 6 MONTH SUSPENSION IN
A SUPERVISORY OR PROPRIETARY CAPACITY. PENALTY WAS BASED ON
MY ROLE IN MUIR'S FINANCIAL COLLAPSE. THE SEC ORDER WAS
AFFIRMED BY THE U.S. COURT OF APPEALS FOR THE D.C. CIR. IN
OCTOBER 1986.


NASD BrokerCheck August 17, 2005 Page 10
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

********************************************************************************
CIVIL JUDICIAL ACTIONS
********************************************************************************
DISCLOSURE INFORMATION


This section contains information regarding civil judicial actions that were
reported to CRD. These actions are disclosable through NASD BrokerCheck and
include injunctions issued by a foreign or domestic court in connection with
investment-related activity, a finding by a domestic or foreign court of a
violation of any investment-related statute(s) or regulation(s), and actions
dismissed by a domestic or foreign court pursuant to a settlement agreement.

Some of the fields in this section of the report may be blank if the information
was not provided to CRD.


** OCCURRENCE COUNTS ** 1 Record(s)

********************************************************************************

** FIELD DEFINITIONS **

* Reporting Source: The form through which details of the civil
judicial action was reported to CRD.

* Date Reported: The date the civil judicial action was reported
to CRD.

* Initiated By: The party that initiated the civil judicial
action (e.g., regulator, foreign financial
regulatory authority, self-regulatory
organization, commodities exchange, etc.).

* Date Initiated: Date the civil judicial action was initiated or
filed.

* Court Details: Details regarding the court the action was
brought in (e.g., name and location of court,
docket/case number, etc.).

* Employing Brokerage Firm: Brokerage Firm where individual broker was
employed when activity occurred that led to the
civil judicial action.

* Allegations: Allegations made against the individual broker
leading to the civil judicial action.

* Current Status: The current status of the civil judicial action
(i.e., pending, on appeal or final).

* Resolution: The resolution of the civil judicial action
(e.g., consent, dismissed, judgment rendered,
settled, withdrawn, etc.).

* Resolution Date: The date the civil judicial action was resolved.

* Sanction Details: Additional details regarding any sanctions
ordered.

* Summary: Details of the circumstances related to the civil
judicial action.

********************************************************************************


****** CIVIL JUDICIAL ACTION (1 of 1) ******


Reporting Source: Regulator (Form U-6)

Date Reported: 04/02/2002

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC")

Date Initiated: 06/16/1983

Court Details: THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK - [SEC VS. RAYMOND
L. DIRKS, ET AL., CASE NO. 82 CIVIL 1166, S.D.N.Y. (WCC)]

Employing Brokerage Firm:

Allegations: SEC NEWS DIGEST ISSUE NO. 83-116 AND LITIGATION RELEASE NO.
10037, DATED JUNE 16, 1983: THE SEC ALLEGED THAT RAYMOND LOUIS
DIRKS ("DIRKS") HAD WILFULLY VIOLATED THE ANTIFRAUD PROVISIONS
OF THE SECURITIES LAWS IN THE UNDERWRITING AND PUBLIC OFFERING
OF A COMPANY.

Current Status: Final

Resolution: Judgment Rendered


NASD BrokerCheck August 17, 2005 Page 11
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

CIVIL JUDICIAL ACTIONS(cont.)

Resolution Date: 06/16/1983

Sanctions
Ordered: Disgorgement/Restitution

Other Sanctions: SUBMIT AN ACCOUNTING

Resolution
Details: THE COURT ORDERED THAT DEFENDANT DIRKS SUBMIT AN ACCOUNTING AND
DISGORGE ALL PROCEEDS OBTAINED.

Summary: THE SEC ANNOUNCED THAT THE U.S. DISTRICT COURT FOR THE SOUTHERN
DISTRICT OF NEW YORK FOUND, FOLLOWING A TRIAL ON THE MERITS,
THAT DEFENDANT DIRKS HAD WILFULLY VIOLATED THE ANTIFRAUD
PROVISIONS OF THE SECURITIES LAWS IN THE UNDERWRITING AND
PUBLIC OFFERING OF A COMPANY. THE COURT DECLINED TO ISSUE AN
ORDER OF INJUNCTION AGAINST DEFENDANT DIRKS.


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/28/2002

Initiated By: SECURITIES AND EXCHANGE COMMISSION

Date Initiated: 02/25/1982

Court Details: U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK; 82 CIV. 1166 (WCC)

Employing Brokerage Firm: JOHN MUIR & CO.

Allegations: THE SEC ALLEGED THAT, AS LIMITED PARTNER OF UNDERWRITER OF
STOCK OFFERING OF REINSURANCE CORPORATION, I VIOLATED THE
ANTI-FRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS BY
CAUSING THE SECURITIES OF THE REINSURANCE CORPORATION TO BE
SOLD PURSUANT TO A MATERIALLY MISLEADING PROSPECTUS.

Current Status: Final

Resolution: Judgment Rendered

Resolution Date: 06/14/1983

Sanctions
Ordered: Disgorgement/Restitution

Resolution
Details: DOCUMENTATION NOT AVAILABLE

Summary: THE LOWER COURT MADE A FINDING OF LIABILITY AND ENTERED AN
ORDER OF DISGORGEMENT, BUT DECLINED TO ISSUE AN INJUNCTION
AGAINST ME (SEC V. SCOTT, 565 F.SUPP. 1513 (1983)). THIS
DECISION WAS UPHELD ON APPEAL (SEC V. CAYMAN ISLANDS
REINSURANCE CORP., LTD., ET AL., 734 F.2D 118 (2D CIR 1984)).




NASD BrokerCheck August 17, 2005 Page 12
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

********************************************************************************
TERMINATIONS
********************************************************************************
DISCLOSURE INFORMATION


This section contains information regarding employment terminations that were
reported to CRD. These events are disclosable through NASD BrokerCheck and
include terminations that resulted in a voluntary resignation, discharge, or
permission to resign after allegations were made that accused the individual
broker of violating investment-related statutes, regulations, rules or industry
standards of conduct, fraud or the wrongful taking of property, or failure to
supervise in connection with investment-related statutes, regulations, rules or
industry standards of conduct.

Some of the fields in this section of the report may be blank if the information was not provided to CRD.

** OCCURRENCE COUNTS ** 1 Record(s)

********************************************************************************

** FIELD DEFINITIONS **

* Reporting Source: The form through which details of the employment
termination was reported to CRD.

* Date Reported: The date the employment termination was reported to
CRD.

* Brokerage Firm Name: Name of the brokerage firm from which the individual
was terminated.

* Termination Type: Type of termination (e.g., voluntary resignation,
permitted to resign, or discharged).

* Termination Date: Date employment was terminated.

* Allegations: Allegations made against the individual broker
leading to the employment termination.

* Summary: Details of the circumstances related to the
termination.


********************************************************************************


*********** TERMINATION (1 of 1) ***********


Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/16/2002

Brokerage Firm Name: COLEMAN & CO.

Termination Type: Voluntary Resignation

Termination Date: 10/16/1995

Allegations: MISAPPROPRIATION OF FUNDS

Summary: COLEMAN ALLEGED THAT MONIES PAID TO RAY DIRKS PURSUANT TO
LETTERS OF INTENT SHOULD HAVE BEEN PAID TO COLEMAN & CO.





























NASD BrokerCheck August 17, 2005 Page 13
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

********************************************************************************
CUSTOMER COMPLAINTS
********************************************************************************

DISCLOSURE INFORMATION


This section contains information regarding customer complaints that were
reported to CRD. These events are disclosable through NASD BrokerCheck and
include consumer-initiated, investment-related arbitration proceedings or civil
suits which contain allegations of sales practice violations against the
individual broker and are either pending, resulted in an award against the
individual broker, or were settled for $10,000 or more. Customer complaint
events also include consumer-initiated, investment-related complaints which
contain allegations of sales practice violations against the individual broker
and which were settled for $10,000 or more, as well as consumer-initiated,
investment-related written complaints filed within the past twenty-four months
which contain either allegations of sales practice violations and damages of
$5,000 or allegations of forgery, theft, or misappropriation of funds or
securities.

Some of the fields in this section of the report may be blank if the information
was not provided to CRD.

The customer complaints listed in this report may include allegations that have
been filed with a brokerage firm, an arbitration forum, or a court, but that
have not been verified or proven to be true. Therefore, you should not assume
that all allegations that may be contained in this report are true or will be
proven to be true. NASD encourages you to discuss any concerns you may have
with the information contained in this report with your brokerage firm or
individual broker, who can provide you with any further information that you
may require.


** OCCURRENCE COUNTS ** 2 Record(s)

********************************************************************************

** FIELD DEFINITIONS **

* Reporting Source: The form through which details of the customer
complaint was reported to CRD.

* Date Reported: The date the customer complaint was reported to
CRD.

* Date Received: Date the complaint was received at the brokerage
firm or filed as an arbitration or civil suit.

* Employing Brokerage Firm: Brokerage Firm where individual broker was
employed when activity occurred that led to the
complaint.

* Allegations: Allegations made against the individual broker
leading to the customer complaint.

* Alleged Damages: Alleged dollar amount of compensatory damages
sought by the customer.

* Action Pending?: An indication (i.e., yes or no) as to whether the
complaint is still pending.

* Status: Status of complaint if not pending (e.g., closed,
resulted in no action taken, withdrawn, denied,
settled, resulted in an arbitration or
litigation, etc.).

* Resolution Date: Date associated with the status of the complaint.
Will be blank if complaint is still pending.

* Settlement Amount: The dollar amount the brokerage firm and/or
individual broker paid the customer to satisfy
the claim.

* Individual Contribution: The dollar amount the indvidual broker
contributed to the settlement amount.

* Arbitration/Reparation DetThe name of the self-regulatory
organization/agency where the claim was filed
and the claim 's docket case number.

* Service Date: The date the brokerage firm/individual broker
received notice of the claim or the date Service
of Process for the claim was received.

* Pending?: An indication (i.e., yes or no) as to whether the
claim is still pending.

* Monetary Compensation: The dollar amount the individual broker paid in
accordance with an arbitration/civil litigation
award, settlement, or reparation.


NASD BrokerCheck August 17, 2005 Page 14
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

CUSTOMER COMPLAINTS(cont.)

* Disposition: Details of the disposition of the arbitration,
reparation or litigation if status of the
complaint indicates either arbitration,
reparation or litigation.

* Disposition Date: The disposition date of the arbitration,
reparation or litigation.

* Summary: Details related to the circumstances of the
complaint.


********************************************************************************


******** CUSTOMER COMPLAINT (1 of 2) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 03/17/2003

Case Filed With: NASD

Date Initiated: 12/15/2000

Case Number: 00-05558

Employing Brokerage Firm:

Allegations: UNAUTHORIZED TRADING, FRAUD, CHURNING

Alleged Damages: $474,500.00

Pending?: No

Disposition: Award

Disposition
Date: 02/24/2003

Disposition
Details: AWARD: RESPONDENT IS LIABLE, JOINTLY AND SEVERALLY, AND SHALL
PAY TO CLAIMANT THE SUM OF $50,000.00 AS COMPENSATORY DAMAGES,
PLUS INTEREST.


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 06/17/2004

Date Received: 02/14/2001

Employing Brokerage Firm: DIRKS & CO. INC.

Allegations: ALLEGED UNAUTHORIZED TRADING IN APRIL 1999

Alleged Damages: $255,000.00

Action Pending?: No

Resolution: Arbitration/Reparation

Resolution
Date: 02/14/2001

Arbitration/Reparation
Details: NASD 00-05558

Service Date: 02/14/2001

Pending?: No

Disposition: Award to Customer

Disposition
Date: 02/24/2003

Monetary Compensation
Amount: $50,000.00

Individual Contribution
Amount: $0.00

Disposition
Details:




NASD BrokerCheck August 17, 2005 Page 15
This information is current as of: 08/17/2005
________________________________________________________________________________
NASD Registered Person: RAYMOND LOUIS DIRKS
CRD Number: 601699

CUSTOMER COMPLAINTS(cont.)

******** CUSTOMER COMPLAINT (2 of 2) ********


Reporting Source: Regulator (Form U-6)

Date Reported: 06/05/2001

Case Filed With: NASD

Date Initiated: 09/28/1999

Case Number: 99-04430

Employing Brokerage Firm:

Allegations: >06/05/01 BREACH OF CONTRACT, NEGLIGENCE, UNSUITABILITY,
UNAUTHORIZED TRADING, MISREPRESENTATION, BREACH OF TRUST

Alleged Damages: $167,500.00

Pending?: No

Disposition: Award

Disposition
Date: 05/04/2001

Disposition
Details: RESPONDENT BE AND HEREBY IS LIABLE FOR AND SHALL PAY TO
CLAIMANT THE SUM OF $59,510.00 AS COMPENSATORY DAMAGES PLUS
INTEREST.


***********************************
Reporting Source: Individual Broker (Form U-4)

Date Reported: 08/16/2002

Date Received: 09/28/1999

Employing Brokerage Firm: NATIONAL SECURITIES CORP.

Allegations: BREACH OF CONTRACT, NEGLIGENCE, UNSUITABILITY, UNAUTHORIZED
TRADING, MISREPRESENTATION, BREACH OF TRUST, FAILURE TO
SUPERVISE

Alleged Damages: $167,500.00

Action Pending?: No

Individual
Contribution: $0.00

Resolution: Arbitration/Reparation

Resolution
Date: 05/04/2001

Arbitration/Reparation
Details: NASD 99-04430

Service Date: 09/28/1999

Pending?: No

Disposition: Award to Customer

Disposition
Date: 05/04/2001

Monetary Compensation
Amount: $59,510.00

Individual Contribution
Amount: $0.00

Disposition
Details:













NASD BrokerCheck August 17, 2005 Page 16
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