MEMBER FIRM: NORTH AMERICAN INSTITUTIONAL BROKERS
BD NUMBER: 20574
NASD Member Firm: NORTH AMERICAN INSTITUTIONAL BROKERS
BD Number: 20574
12/15/98 SUMMARY INFORMATION
12/15/98: 4/27/98 NASD CENSURE AND FINE
ACCEPTANCE, WAIVER AND CONSENT; CENSURED AND FINED $8,500 BY THE NASD. THE
NASD ALLEGED THAT THE FOLLOWING ACTIVITY OCCURRED: FIRM FAILED TO DESIGNATE AS
LATE TO ACT ONE TRANSACTION; FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO
ACT IN ONE TRANSACTION; FAILED TO PROVIDE ON FORM T THE TIME OF EXECUTION FOR
FOUR TRANSACTIONS; FAILED TO PROVIDE ON FORM T A SYMBOL INDICATING WHETHER
FIVE TRANSACTIONS WERE A BUY, SELL, OR CROSS; AND FAILED TO PROVIDE ON FORM T
THAT TWO TRANSACTIONS WERE CANCELLED IN VIOLATION OF NASD MARKETPLACE RULES
4632(a), 4632(a)(5), AND 4632(c). FIRM FAILED TO DESIGNATE AS LATE TO ACT TWO
TRANSACTIONS; FAILED TO REPORT TO ACT ONE TRANSACTION; FAILED TO PROVIDE ON
FORM T THE TIME OF EXECUTION FOR TWO TRANSACTIONS; FAILED TO PROVIDE ON FORM T
A SYMBOL INDICATING WHETHER TWO TRANSACTIONS WERE A BUY, SELL, OR CROSS; AND
FAILED TO PROVIDE ON FORM T THAT ONE TRANSACTION WAS CANCELLED IN VIOLATION OF
NASD MARKETPLACE RULE 4642(a) AND 4642(a)(5). FIRM FAILED TO DESIGNATE AS LATE
TO ACT FOUR TRANSACTIONS; FAILED TO REPORT TO ACT TWO TRANSACTIONS; AND FAILED
TO PROVIDE ON A FORM T THE TIME OF EXECUTION FOR ONE TRANSACTION. THIS CONDUCT
INVOLVING OTC EQUITY SECURITIES CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS
OF NASD MARKETPLACE RULES 6620, 6620(a) AND 6620(a)(4). FIRM FAILED TO
PRESERVE, FOR A PERIOD OF NOT LESS THAN SIX YEARS, MEMORANDA OF ONE BROKERAGE
ORDER; FAILED TO SHOW TERMS AND CONDITIONS ON MEMORANDA OF EIGHT BROKERAGE
ORDERS; FAILED TO SHOW ON A MEMORANDA OF ONE BROKERAGE ORDER THE CORRECT TIME
OF ENTRY; AND FAILED TO SHOW ON MEMORANDA OF TWO BROKERAGE OREDRS THE CORRECT
TIME OF EXECUTION IN VIOLATION OF NASD CONDUCT RULES 3110 AND 3110(a). IN
ADDITION, FIRM FAILED TO ESTABLISH AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE
SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING, BEST EXECUTION,
RECORD KEEPING, AND THE LIMIT ORDER PROTECTION INTERPRETATION IN VIOLATION OF
NASD CONDUCT RULES 2110 AND 3010.***$8,500.00 PAID ON 6/18/98, INVOICE
#98-MS-484***[NASD COMPLAINT NO. CMS980044 AWC]hk
12/15/98: 2/23/93 NASD FINE
ACCEPTANCE, WAIVER AND CONSENT; NORTH AMERICAN INSTITUTIONAL BROKERS WAS FINED
$1,000 BY THE NASD FOR ALLEGED VIOLATIONS OF PART VI SECTION 2(d) OF SCHEDULE
1
D FOR ENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS. ***$1,000 PAID ON
3/11/93 INVOICE #93-MS-168***[NASD COMPLAINT NO. CMS920106 (AWC) (A)]hk
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