brokercheck report stratton oakmont inc

BrokerCheck Report

STRATTON OAKMONT INC.CRD# 18692Report # 559259 generated on Thursday, June 28, 2007.

Dear Investor:

FINRA has generated the following BrokerCheck reportfor STRATTON OAKMONT INC.. The informationcontained within this report has been provided by aFINRA brokerage firm(s) and securities regulators aspart of the securities industry’s registration andlicensing process and represents the most currentinformation reported to the Central RegistrationDepository (CRD®).

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©2007 FINRA. All rights reserved. Report# 559259 generated on Thursday, June 28, 2007 about STRATTON OAKMONT INC. 1

STRATTON OAKMONT INC.

CRD# 18692

SEC# 8-36919

Main Office Location1979 MARCUS AVE STE 120LAKE SUCCESS, NY 11042United States

Mailing Address1979 MARCUS AVENUELAKE SUCCESS, NY 11042-1002United States

Report Summary for this Firm

This firm is no longer registered with FINRA. The firm’s registration with FINRA was terminated (e.g.,voluntarily withdrawn, cancelled, liquidated, expelled) prior to August 1999 when the enhanced CentralRegistration Depository System (i.e. Web CRD®) was implemented. As a result, since the firm was notrequired to update its CRD record via the submission of an electronic Form BD filing to Web CRD, FINRA’sBrokerCheck program contains only limited information about this firm.

Firm Profile

This firm is classified as CORPORATION.

This firm was formed in New York on10/23/1986.

Its fiscal year ends in September.

Firm Operations

This firm is no longer registered withFINRA.

Disclosure of Arbitration Awards,Disciplinary and Regulatory EventsThis section includes details regarding disclosureevents reported by or about this firm to CRD aspart of the securities industry registration andlicensing process. Examples of such disclosureevents range from disciplinary actions initiated byregulators to certain criminal charges and/orconvictions, to financial disclosures such asbankruptcies, and summary information regardingarbitration awards involving securities andcommodities disputes between public customersand FINRA-registered firms.



Firm Profile

This firm is classified as a CORPORATION.

This firm was formed in New York on 10/23/1986.

Its fiscal year ends in September.

Firm Names and LocationsThis section includes details, as reported by the firm on Form BD, regarding the firm’s full legal name, business andmailing addresses, the firm’s “doing business as” name (i.e. “DBA” name) if different from the full legal name, andany other name by which the firm conducts business and where such name is used.

STRATTON OAKMONT INC.

Doing business as STRATTON OAKMONT INC.

CRD# 18692

SEC# 8-36919

Main Office Location

1979 MARCUS AVE STE 120LAKE SUCCESS, NY 11042United States

Mailing Address

1979 MARCUS AVENUELAKE SUCCESS, NY 11042-1002United States

Business Telephone Number

516-358-1800



Firm ProfileThis section provides information relating to Direct Owners and Executive Officers as reported by the firm on Form BD.

Direct Owners and Executive Officers

Information not available – see Summary Page.



Firm ProfileThis section provides information relating to Indirect Owners, if any, as reported by the firm on Form BD.

Indirect Owners




Firm HistoryThis section provides information relating to successions (e.g. mergers or acquisitions), if any, as reported by the firm on Form BD.




Firm Operations

RegistrationsThis section provides information about the regulators (e.g. U.S. Securities and Exchange Commission (SEC), self-regulatory organizations, states and U.S. territories) the firm is currently registered with, the category of eachregistration, and the date on which the registration status became effective, as well as certain information about thefirm’s SEC registration.

This firm is no longer registered with FINRA.

The firm’s registration with FINRA was from 4/2/1987 to 1/28/1997.

SEC Registration QuestionsThis firm was registered with the SEC as:

A broker-dealer only: Information not available – see Summary Page.

A broker-dealer and government securities broker or dealer: No

A government securities broker or dealer only: No

The firm has ceased activity as a government securities broker or dealer: No



Types of BusinessThis section provides the types of business and any other business or other non-securities business the firm isengaged in or is expected to be engaged in as reported by the firm on Form BD.

This firm conducted 6 types of business.

Exchange member engaged in exchange commission business other than floor activities NoExchange member engaged in floor activities NoBroker or dealer making inter-dealer markets in corporate securities over-the-counter YesBroker or dealer retailing corporate equity securities over-the-counter YesBroker or dealer selling corporate debt securities NoUnderwriter or selling group participant (corporate securities other than mutual funds) YesMutual fund underwriter or sponsor NoMutual fund retailer YesU.S. government securities dealer NoU.S. government securities broker NoMunicipal securities dealer NoMunicipal securities broker YesBroker or dealer selling variable life insurance or annuities NoSolicitor of time deposits in a financial institution NoReal estate syndicator NoBroker or dealer selling oil and gas interests NoPut and call broker or dealer or option writer YesBroker or dealer selling securities of only one issuer or associate issuers (other than mutual funds) NoBroker or dealer selling securities of non-profit organizations (e.g., churches, hospitals) NoInvestment advisory services NoBroker or dealer selling tax shelters or limited partnerships in primary distributions NoBroker or dealer selling tax shelters or limited partnerships in the secondary market NoNon-exchange member arranging for transactions in listed securities by exchange member NoTrading securities for own account NoPrivate placements of securities NoBroker or dealer selling interests in mortgages or other receivables NoBroker or dealer involved in a networking kiosk or similar arrangement with a bank, savings bank orassociation, or credit union

No

Broker or dealer involved in a networking kiosk or similar arrangement with a Insurance company oragency

No



Other Types of Business

This firm does not affect transactions in commodities, commodity futures, or commodity options.

This firm does not engage in other non-securities business.



Clearing Arrangements

Information not available – see Summary Page

Introducing Arrangements


Industry Arrangements


Organization Affiliates




Disclosure of Arbitration Awards, Disciplinary and Regulatory Events

Firms are required to answer a series of disclosure questions on Form BD and provide the corresponding details to anyreported events as part of the securities industry registration and licensing process. The disclosure questions concerncriminal and regulatory events, civil actions, and certain financial disclosures such as bankruptcy or liquidationproceedings filed within the past ten years, bond actions and unpaid judgments and liens. The firm must answer either“yes” or “no” to each question as it applies to the firm itself or to any of its control affiliates (i.e., an individual, partnership,corporation, trust, or other organization that directly or indirectly controls, is under common control with, or is controlledby the firm). This section lists the various disclosure questions and their corresponding answers as reported by the firmon Form BD.

Possible multiple reporting sources –please note:

Disclosure event details may bereported by more than one source (i.e.,regulator or firm). When this occurs, allversions of the reported event willappear in the firm’s BrokerCheckreport.



Disclosure Event Details

This section provides the specific details for each disclosure event, as reported by the firm on Form BD, thatcorrespond with any “yes” answers to the various Form BD disclosure questions. It also includes summary informationregarding arbitration awards in cases where the firm was named as a respondent in the arbitration proceeding, if any.

Nothing will be displayed in this section of the firm’s BrokerCheck Report when the firm has no reported disclosureinformation.

If the firm does have reported disclosure events, please keep the following in mind when evaluating the disclosureevent details. Items may involve pending actions or allegations that may be contested and have not been resolved orproven. The items may, in the end, be withdrawn or dismissed, or resolved in favor of the firm, or concluded through anegotiated settlement with no admission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD by the firm and/or by securities industryregulators. Some of the specific data fields contained in this section of the report may be blank if the information wasnot provided to CRD.

Disclosure event details may be reported by more than one source (i.e., regulator and firm). When this occurs, allversions of the reported event will appear in the firm’s BrokerCheck report.


©2007 FINRA. All rights reserved. Report# 559259 generated on Thursday, June 28, 2007 about STRATTON OAKMONT INC.

Regulatory - Final

This section provides information regarding any final, regulatory action as reported by the firm and/or a securitiesregulator to CRD as part of the securities industry registration and licensing process. Such event may include a final,formal proceeding initiated by a regulatory authority (e.g., a state securities agency, a self-regulatory organization, afederal regulator such as the U.S. Securities and Exchange Commission (SEC) or the Commodity Futures TradingCommission (CFTC), or a foreign financial regulatory body) for a violation of investment-related rules or regulations. Inaddition, a revocation or suspension of the authority of a firm’s control affiliate to act as an attorney, accountant orfederal contractor, if any, will appear here.

Disclosure

Reporting Source: REGULATOR (U6)

Current Status: FINAL

Allegations: RESPONDENT STRATTON ENGAGED IN VIOLATIONS OF THE MARYLANDSECURITIES ACT INCLUDING SECTIONS 11-301 (FRAUD IN THE OFFER ANDSALE OF SECURITIES); 11-4012 (ACTING AS AN UNREGISTERED BROKER-DEALER); 11-402 (EMPLOYING AN UNREGISTERED BROKER-DEALER AGENT);AND 11-501 (OFFER AND SALE OF UNREGISTERED SECURITIES IN MARYLAND).RESPONDENT ENGAGED IN ABUSIVE SALES PRACTICES THAT RESULTED INMORE THAN 100 COMMPLAINTS FROM MARYLAND RESIDENTS AND PERSONSWHO DID BUSINESS WITH STRATTON WHILE THE COMPANY WAS LOCATED INMARYLAND AT A BRANCH OFFICE IN BETHESDA. RESPONDENT ALSO VIOLATEDA PRIOR ORDER OF THE COMMISSIONER BY FAILING TO REPORT COMPLAINTSTO THE MARYLAND DIVISION OF SECURITIES IN THE PERIOD OF TIMESPECIFIED IN THAT ORDER.

Initiated By: THE MARYLAND DIVISION OF SECURITIES

Date Initiated:

Docket/Case Number: S-94-046

Principal Product Type:

Other Product Type(s):

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:



Resolution: ORDER

Resolution Date: 6/9/1997

Sanctions Ordered:

Other Sanctions Ordered:

Sanction Details: ON JUNE 9, 1997, THE MARYLAND SECURITIES COMMISSIONER ISSUED A FINALORDER, ORDERING THAT THE BROKER-DEALER REGISTRATION OFRESPONDENT WAS REVOKED AS OF JUNE 26, 1995; THAT STRATTON SHALLPERMANENTLY CEASE AND DESIST FROM ENGAGING IN THE OFFER AND SALEOF SECURITIES IN VIOLATION OF SECTIONS 11-301, 11-401 AND 11-501 OF THESECURITIES ACT AND FROMM EMPLOYING UNREGISTERED SECURITIESAGENTS IN VIOLATION OF SECTION 11-402 OF THE SECURITIES ACT; AND THATSTRATTON SHALL ALSO PERMANENTLY CEASE AND DESIST FROM VIOLATINGTHE CONSENT ORDER ISSUED BY THE SECURITIES COMMISSIONER ON MAY10, 1994. THE SECURITIES COMMISSIONER ALSO FINED STRATTON $1,245,000TO BE MITIGATED BY ANY RESTITUTION PAID TO MARYLAND INVESTORS.



Regulatory - Final


Disclosure



Allegations: STRATTON OAKMONT INC. WAS THE SUBJECT OF A PERMANENT COURTINJUNCTION INVOLVING AN ASPECT OF THE SECURITIES BUSINESS.

Initiated By: OR SECURITIES

Date Initiated:

Docket/Case Number: O-95-0037





Resolution: ORDER


Sanctions Ordered:


Sanction Details: THIS WAS A CONSENT ORDER SIGNED ON BEHALF OF STRATTON OAKMONT,INC. BY THE ATTORNEY FOR THE SIPA RECEIVER. THE OREGON LICENSE FORSTRATTON OAKMONT IS REVOKED.



Regulatory - Final


Disclosure



Allegations: AN ORDER INSTITUTING PUBLIC ADMINISTRATIVE PROCEEDINGS, MAKINGFINDINGS AND IMPOSING REMEDIAL SANCTIONS WAS ISSUED BY THESECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") ON MARCH 17,1994. THE COMMISSION FOUND THAT STRATTON WILLFULLY VIOLATEDSECTION 17(a) OF THE SECURITIES ACT OF 1933 AND SECTION 10(b) OF THEEXCHANGE ACT AND RULE 10b-5 THEREUNDER IN THAT STRATTON, THROUGHITS REGISTERED REPRESENTATIVES, ENGAGED IN FRAUDULENT SALESPRACTICES, MADE BASELESS PRICE PREDICTIONS WITH REGARD TO OVER-THE-COUNTER SECURITIES RECOMMENDED BY STRATTON, MADE MATERIALMISREPRESENTATIONS AND OMISSIONS CONCERNING THOSE SECURITIESAND ENCOURAGED AND/OR PERMITTED UNAUTHORIZED TRADING INSTRATTON CUSTOMER ACCOUNTS. THE COMMISSION FOUND THAT STRATTON,ON OR ABOUT JANUARY 1991 TO ON OR ABOUT APRIL 1991, KNOWINGLY ORRECKLESSLY MANIPULATED THE MARKET PRICE OF THE SECURITIES OF NOVACAPITAL, INC. BY DOMINATING AND CONTROLLING THE MARKET FOR NOVACOMMON STOCK AND ENGAGING IN FRAUDULENT SALES PRACTICES.RESPONDENT STRATTON IS THE SUBJECT OF A DETERMINATION AFTERNOTICE AND OPPORTUNITY FOR HEARING, WITHIN THE LAST FIVE YEARS BYTHE COMMISSION, THAT RESPONDENT STRATTON VIOLATED THE SECURITIESACT OF 1933 AND THE EXCHANGE ACT OF 1934, AND THE VIOLATIONS WOULDHAVE CONSTITUTED VIOLATIONS OF THE NEW MEXICO SECURITIES ACT OF1986 HAD THEY TAKEN PLACE IN THIS STATE. THIS DETERMINATION BY THECOMMISSION IS GROUNDS FOR DENIAL,N SUSPENSION OR REVOCATION OFLICENSURE UNDER SECTION 58-13B-16(A)(2) (c) OF THE ACT. ON DECEMBER 5,1996 A DECISION WAS ISSUED BY THE NATIONAL BUSINESS CONDUCTCOMMITTEE ("NBCC") OF THE NASD EXPELLING RESPONDENT STRATTON



FROM MEMBERSHIP IN THE NASD FOR VIOLATIONS OF THE NASD RULES OFFAIR PRACTICE ("NASD RULES"), ARTICLE III, SECTIONS 1, 4, 18 AND 27 (NOWCONDUCT RULES 2110, 2440, 2120, AND 3010, RESPECTIVELY). RESPONDENTSTRATTON'S EXPULSION FROM MEMBERSHIP IN A SELF-REGULATORYORGANIZATION IS GROUNDS FOR DENIAL, SUSPENSION, OR REVOCATION OFLICENSURE UNDER SECTION 15-13B-16(A)(2)(g) OF THE ACT.

Initiated By: NEW MEXICO SECURITIES DIVISION

Date Initiated:

Docket/Case Number: 96-017





Resolution: BARRED


Sanctions Ordered:


Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM VIOLATING THE ACT ANDRULES PROMULGATED THEREUNDER. RESPONDENT IS ORDERED TO PAY ACIVIL PENALTY IN THE AMOUNT OF $20,000 PLUS THE COSTS OFINVESTIGATION IN THE AMOUNT OF $500; AND RESPONDENT IS PERMANENTLYBARRED FROM ASSOCIATION WITH ANY LICENSED BROKER-DEALER ORINVESTMENT ADVISER IN THIS STATE.



Regulatory - Final


Disclosure



Allegations: STRATTON'S BROKER-DEALER REGISTRATION WAS REVOKED BY NEW JERSEYIN JULY 1996 AND BY NEW HAMPSHIRE IN DECEMBER 1996. ADDITIONALLY,STRATTON WAS EXPELLED FROM THE NASD IN DECEMBER 1996.

Initiated By: KANSAS SECURITIES COMMISSIONER

Date Initiated:

Docket/Case Number: 97E034/96-3070





Resolution: ORDER


Sanctions Ordered:


Sanction Details: STRATTON'S BROKER-DEALER REGISTRATION IS REVOKED.



Regulatory - Final


Disclosure



Allegations:

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated:

Docket/Case Number:





Resolution: DECISION


Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10970013 FILED JANUARY 23, 1997 BY DISTRICT NO. 10AGAINST STRATTON OAKMONT, INC. ALLEGING VIOLATIONS OF NASD RULES2110 AND 2120 IN THAT RESPONDENT MEMBER, ACTING THROUGH ITSREGISTERED PRINCIPALS AND REGISTERED REPRESENTATIVES, ENGAGED INA PRACTICE OF EXECUTING UNAUTHORIZED TRANSACTIONS IN THE



ACCOUNTS OF ITS CUSTOMERS WITHOUT THE PRIOR KNOWLEDGE, CONSENT,OR AUTHORIZATION OF THE CUSTOMERS. ON JUNE 29, 1998, THE DECISIONAND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BYRESPONDENT MEMBER WAS ISSUED; THEREFORE, RESPONDENT MEMBER ISEXPELLED FROM NASD MEMBERSHIP.



Regulatory - Final


Disclosure



Allegations: FAILURE TO COMPLY WITH SUSPENSION ORDER NO. 95-26-S, FAILURE TOSUPERVISE ITS AGENTS

Initiated By: ARKANSAS SECURITIES DEPARTMENT

Date Initiated:

Docket/Case Number: 96-95-S





Resolution: ORDER


Sanctions Ordered:


Sanction Details: ORDER NO. 96-95-S REVOKING REGISTRATION AS A BROKER-DEALER INARKANSAS. STRATTON OAKMONT, INC. WAS REGISTERED IN ARKANSAS AS ABROKER-DEALER FROM FEBRUARY 15, 1990, UNTIL IT WAS SUMMARILYSUSPENDED FROM DOING SECURITIES BUSINESS IN ARKANSAS ON APRIL 28,



1996, PURSUANT TO ORDER NO. 95-26-S WHICH WAS BASED UPON THEPERMANENT INJUNCTION ISSUED AGAINST STRATTON OAKMONT BY THEUSDC FOR THE DISTRICT OF COLUMBIA ON FEBRUARY 28, 1995. STRATTONOAKMONT FAILED TO COMPLY WITH THE ARKANSAS SUSPENSION ORDER ANDCONTINUED TO EFFECT SECURITIES TRANSACTIONS WITH CUSTOMERS INARKANSAS. A COMPLAINT WAS ENTERED ON DECEMBER 23, 1996 AND AHEARING WAS SET FOR JANUARY 13, 1997. STRATTON OAKMONT FAILED TOSHOW FOR THE HEARING AND ITS REGISTRATION WAS REVOKED AND IT WASFINED $5,000 FOR EACH OF FIFTEEN (15) VIOLATIONS OF THE ACT FOR ATOTAL OF $75,000.



Regulatory - Final


Disclosure



Allegations: 1-51-410 DENIAL, SUSPENSION OR REVOCATION BASED ON NASD EXPULSIONOF FIRM AND BAR OF DANIEL PORUSH AND STEVEN SANDERS.

Initiated By: COLORADO DIVISION OF SECURITIES

Date Initiated:

Docket/Case Number: XY 97-01





Resolution: ORDER


Sanctions Ordered:


Sanction Details: 12/05/96 THE NASD EXPELLED STRATTON OAKMONT AND ORDEREDRESTITUTION OF $416,528.77, BARRED DANIEL PORUSH AND FINED $250,000.BARRED STEVEN SANDERS AND FINED $25,000. FOR FRAUDULENT MARK-UP'SON A PENNY STOCK. CONTACT: TERRY BOLTE 303-894-2320



Regulatory - Final


Disclosure



Allegations:

Initiated By: NH

Date Initiated:

Docket/Case Number: 94-005





Resolution: ORDER


Sanctions Ordered:


Sanction Details: ON MAY 1, 1996 THE BUREAU ENTERED INTO A CONSENT ORDER WITHRESPONDENT STRATTON OAKMONT, INC.. WHEREBY STRATTON WITHDREWITS BD LICENSE FROM THE STATE, PAID ADMINISTRATIVE ASSESSMENT OF$50,000, AND AGREED TO RESOLVE ALL NEW HAMPSHIRE COMPLAINTSTHROUGH MEDIATION. HOWEVER, AS A RESULT OF FAILING TO COMPLY WITH



THE TERMS OF THE CONSENT ORDER, STRATTON'S LICENSE WAS REVOKEDBY DEFAULT ORDER.



Regulatory - Final


Disclosure



Allegations: ENGAGED IN A PATTERN OF WILLFUL VIOLATION OF FEDERAL SECURITIESLAWS AND INTENTIONAL EVASION OF ITS RESPONSIBLITIES UNDER AN ORDEROF THE FEDERAL SEC AND UNDER A TRO AND PRELIMINARY INJUCTION OF AFEDERAL DISTRICT CT

Initiated By: MN

Date Initiated:

Docket/Case Number: SE9502163/LMD





Resolution: ORDER


Sanctions Ordered:


Sanction Details: REVOCATION PURSUANT TO FINDINGS OF FACT, CONCLUSIONS OF LAW ANDORDER



Regulatory - Final


Disclosure



Allegations: ON NOVEMBER 1, 1996, A NOTICE TO PRODUCE FINANCIAL AND COMPLIANCEREPORTS PURSUANT TO A CONSENT ORDER OFMAY 28, 1996 WAS SERVED ONSTRATTON OAKMONT. THE FIRM FAILED TO COMPLY. IT FAILED TO FUND ANDMAINTAIN THE MEDIATION ESCROW ACCOUNT REQUIRED BY THE CONSENTORDER. IT FAILED TO MAINTAIN THE SEGREGATED ACCOUNT REQUIRED BYTHE CONSENT ORDER. IT FAILED TO PAY ARBITRATION, MEDIATION ORAGREED UPON SETTLEMENTS TO GEORGIA CITIZENS. IT FAILED TO PROVIDECURRENT FINANCIAL INFORMATION REGARDING ITS OPERATION IN THESTATE.

Initiated By: GEORGIA SECURITIES COMMISSIONER

Date Initiated:

Docket/Case Number: 50-95-0050





Resolution: ORDER




Sanctions Ordered:


Sanction Details: IT IS HEREBY ORDERED THAT STRATTON OAKMONT, INC. BE SUSPENDEDFROM REGISTRATION IN GEORGIA EFFECTIVE UPON THE DATE OF THISORDER.



Regulatory - Final


Disclosure



Allegations: NOTICE OF INTENT TO REVOKE STRATTON'S BROKER-DEALER LICENSE WASISSUED. PRIOR TO A HEARING ON THE MERITS, STRATTON VOLUNTARILYWITHDREW REGISTRATION AS A BROKER-DEALER IN SOUTH CAROLINA.

Initiated By: SOUTH CAROLINA DIVISION OF SECURITIES

Date Initiated:

Docket/Case Number: 95099





Resolution: ORDER


Sanctions Ordered:


Sanction Details: ULTIMATELY A CONSENT ORDER WAS NEGOTIATED PURSUANT TO WHICHSTRATTON PLED GUILTY TO FAILING TO REASONABLY SUPERVISE CERTAIN OFITS AGENTS AND AGREED TO SET UP A CLAIMS RESOLUTION PROCESS TO



SPEED HEARINGS ON INVESTOR CLAIMS.



Regulatory - Final


Disclosure



Allegations: THE DESIGNATED BUREAU CHIEF AFFIRMED IN FULL THE INITIAL DECISION OFTHE ADMINISTRATIVE LAW JUDGE REVOKING THE BD REGISTRATION OFSTRATTON OAKMONT BASED ON ITS BEING IN THE PUBLIC INTEREST (49:3-58(a)(1) AND A COURT OF COMPETENT JURISDICTION HAVING ENJOINEDRESPONDENTS FROM CONDUCT IN THE SECURITIES BUSINESS.

Initiated By: STATE OF NEW JERSEY BUREAU OF SECURITIES

Date Initiated:

Docket/Case Number: BOS 04500-95N





Resolution: ORDER


Sanctions Ordered:


Sanction Details:



Regulatory - Final


Disclosure



Allegations: ON 6/13/96, THE CT DEPT. OF BANKING ISSUED A NOTICE OF INTENT TOREVOKE THE BROKER-DEALER REGISTRATION OF STRATTON OAKMONT, INC.THE ACTION WAS BASED ON A 2/28/95 PERMANENT INJUNCTION BY THE U.S.DISTRICT COURT FOR THE DISTRICT OF COLUMBIA; CERTAIN SANCTIONSIMPOSED BY THE NASD; AND SUSPENSION ORDERS ENTERED BY VARIOUSSTATES. IN ADDITION, THE DEPT. ALLEGED THAT STRATTON HAD ENGAGED INDISHONEST OR UNETHICAL BUSINESS PRACTICES BY FALSIFYINGCUSTOMERS' NET WORTH AND/OR ANNUAL INCOME FIGURES ON NEWACCOUNT FORMS; MADE MATERIAL MISREPRESENTATIONS IN CONNECTIONWITH A DEPT. INVESTIGATION; WILFULLY FILED A FALSE OR MISLEADINGSTATEMENT WITH THE AGENCY; AND WILFULLY FAILED TO FURNISH ACCESSTO ALL AREAS OF ITS SECURITIES OPERATIONS DURING THE COURSE OF ADEPT. EXAMINATION.

THIS IS AN UPDATE TO INCIDENT 36: CONSENT ORDER ENTERED 11/1/96RESOLVING MATTERS IN 6/13/96 NOTICE OF INTENT TO SUSPEND OR REVOKEREGISTRATION AS A BROKER-DEALER.

Initiated By: CONNECTICUT DEPT. OF BANKING

Date Initiated:

Docket/Case Number: NR-96-2615-S and CO-96-2615-S







Resolution: ORDER


Sanctions Ordered:


Sanction Details: 6/13/96 NOTICE OF INTENT TO REVOKE REGISTRATION ISSUED. RESPONDENTFIRM AFFORDED AN OPPORTUNITY FOR A HEARING ON THE NOTICE OFINTENT TO REVOKE.

TERMS OF 11/1/96 CONSENT ORDER INCLUDED: 1) PRESERVING INVESTORRIGHTS TO PARTICIPATE IN THE NASD CLAIMS MEDIATION/ARBITRATIONPROCESS; 2) RESTRICTION ON SOLICITED TRADING ACTIVITY FOR 30CONSECUTIVE CALENDAR DAYS STARTING 10/17/96; 3) QUARTERLYACCOUNTINGS OF FUNDS ESCROWED IN CONNECTION WITH THE CLAIMS/MEDIATION PROCESS; 4) FOR 2 YEARS, FIRM MAY ONLY CONDUCT BUSINESSWITH "ACCREDITED" CT RESIDENTS; 5) A RESCISSION OFFER TO THOSEINVESTORS PURCHASING SECURITIES THROUGH THE FIRM FROM 1/1/95 ON; 6)REQUIREMENT THAT STRATTON RETAIN GENERAL COUNSEL; 7)REQUIREMENTTHAT THE NUMBER OF OUTSIDE DIRECTORS BE INCREASED TO ENSURE THATTHEY CONSTITUTE A MAJORITY OF THE ENTIRE BOARD; 8) REQUIREMENTTHAT THE FIRM NOTIFY THE DEPT. AT LEAST 10 BUSINESS DAYS BEFORE ANYLIQUIDATION, ASSET SALE, REORGANIZATION OR OTHER STRUCTURALMODIFICATION; 9) REQUIREMENT THAT BOARD MEMBERS & GENERALCOUNSEL EXECUTE AN ACKNOWLEDGMENT OF FIDUCIARY RESPONSIBILITYAS PART OF CONSENT ORDER; 10) REQUIREMENT THAT ALL PRINCIPALS &MANAGERS SERVICING CT ACCOUNTS COMPLETE CONTINUING EDUCATIONWITHIN 60 DAYS OF 11/1/96; 11) RANDOM TAPING OF COLD CALLS & RETENTIONOF TAPES FOR FEDERALLY PRESCRIBED PERIODS; 12) REQUIREMENT THATCOLD CALLERS CALLING IN OR FROM CT BECOME REGISTERED AS AGENTS;13) QUARTERLY REPORTING OF COMPLAINTS FOR 2 YEARS; AND 14) $50,000FINE PLUS $12,500 INVESTIGATIVE COSTS (TOTAL: $62,500).



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10960080 FILED JUNE 6, 1996 BY DISTRICT NO. 10 AGAINSTSTRATTON OAKMONT INC., DANIEL M. PORUSH, STEVEN P. SANDERS, IRVINGSTITSKY, AND, JORDAN I. SHAMAH ALLEGING VIOLATIONS OF ARTICLE III,SECTIONS 1, 4, 18 AND 27 OF THE RULES OF FAIR PRACTICE AND SECTION10(b) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULES 10b-5 AND



10b-6 THEREUNDER IN THAT RESPONDENT MEMBER, ACTING THROUGHRESPONDENTS PORUSH AND SANDERS, DURING THE PERIOD JUNE 1993THROUGH APRIL 1994 (THE REVIEW PERIOD), ENGAGED IN, AND INDUCEDOTHERS TO ENGAGE IN: A) THE USE OF MANIPULATIE OR DECEPTIVE DEVISESAND FRAUDULENT SCHEMES TO DEFRAUD; B) THE USE OF UNTRUESTATEMENTS OF MATERIAL FACT AND THE OMISSION TO STATE MATERIALFACTS NECESSARY TO MAKE STATEMENTS MADE, IN LIGHT OF THECIRCUMSTANCES, NOT MISLEADING; AND, C) ACTS, PRACTICES, OR COURSESOF BUSINESS WHICH OPERATE AS A FRAUD OR DECEIT UPON PERSONS INCONNECTION WITH THE PURCHASE AND SALE OF SECURITIES OF FIVEISSUERS. RESPONDENTS MEMBER, PORUSH AND SANDERS ALSO FAILED TOOBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST ANDEQUITABLE PRINCIPLES OF TRADE IN CONNECTION WITH THE FIRMSPURCHASE AND SALE OF THE SECURITIES OF FIVE ISSUERS. SUCHMANIPULATIVE, FRAUDULENT AND DECEPTIVE ACTS BY RESPONDENTMEMBER, THROUGH RESPONDENTS PORUSH AND SANDERS, INCLUDES APATTERN AND PRACTICE OF ACTIVITY IN THE SECURITIES OF FIVE ISSUERSINCLUDING: A) THE SALE OF LARGE QUANTITIES OF SECURITIES IN INITIALPUBLIC OFFERINGS TO CERTAIN CUSTOMERS WITH PREARRANGEMENT THATSUCH CUSTOMERS WOULD SELL OR FLIP THE SECURITIES BACK TORESPONDENT MEMBER AT A PREDETERMINED PRICE IN THE IMMEDIATEAFTERMARKET; B) THE BIDDING OR PURCHASING FOR A PROPRIETARYACCOUNT OF RESPONDENT MEMBER IN THE SECURITIES OF FIVE ISSUERSPRIOR TO RESPONDENT MEMBER COMPLETING ITS DISTRIBUTION TO PUBLICINVESTORS; AND, C) PRIOR TO THE CLOSE OF EACH OF THE FIVE OFFERINGS,PRE-SELLING THE AFTERMARKET IN THESE SECURITIES BY SOLICITINGCUSTOMERS TO PURCHASE IN THE AFTERMARKET, AND COMMITTINGCUSTOMERS TO BUY IN THE AFTERMARKET AS A CONDITION OF OBTAININGALLOCATIONS IN THE IPO. THESE SECURITIES INCLUDE THE UNITS ANDCOMPONENTS ISSUED BY COMPUTER MARKETPLACE, INC., MASTER GLAZIERKARATE INTERNATIONAL, INC., STEVEN MADDEN, LTD., M. H. MEYERSON & CO.,INC., AND IDM ENVIRONMENTAL CORP. DURING THE REVIEW PERIOD.THROUGH MANIPULATIVE, FRAUDULENT AND DECEPTIVE ACTS, RESPONDENTMEMBER, ACTING THROUGH RESPONDENTS PORUSH AND SANDERS,REALIZED AGGREGATE ILLEGAL PROFITS OF APPROXIMATELY $28,000,000DURING JUST THE FIRST DAY OF AFTERMARKET TRADING IN THE SECURITIESOF EACH OF FIVE ISSUERS; DURING EACH OF FIVE PUBLIC OFFERINGSRESPONDENT MEMBER SOLD TO ITS OWN CUSTOMERS BETWEEN 58 AND 90PERCENT OF THE TOTAL DISTRIBUTION; DURING THE OFFERING,RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS PORUSH ANDSANDERS, PLACED BETWEEN 41 AND 55 PERCENT OF RESPONDENT MEMBERS



TOTAL ALLOCATION INTO CUSTOMER ACCOUNTS IN WHICH THEY EITHERSIMULTANEOUSLY WITH CONFIRMATION OF INDICATIONS OF INTERESTARRANGED WITH THOSE CUSTOMERS TO SELL, OR REASONABLY BELIEVEDWOULD SELL ITS OFFERING UNITS TO RESPONDENT MEMBER ATPREDETERMINED PRICES IN THE IMMEDIATE AFTERMARKET TRADING OF THESECURITY. RESPONDENT MEMBER, ACTING THROUGH RESPONDENTSPORUSH AND SANDERS, KNEW OR REASONABLY SHOULD HAVE KNOW THATTHESE CUSTOMERS WERE GOING TO SELL THEIR IPO UNITS TO RESPONDENTMEMBER AT PREDETERMINED PRICES, BOTH THROUGH SUCHPREARRANGEDMENT WITH SUCH ACCOUNTS, AND AS EVIDENCED BY THETRADING OF EACH OFFERING AND BY THE PATTERN OF TRADING IN THESEOFFERINGS. RESPONDENTS PORUSH AND SANDERS WERE THUS AWARE, ORREASONABLY SHOULD HAVE BEEN AWARE, THAT THESE CUSTOMERS DID NOTHAVE BONA FIDE INVESTMENT INTENT AND DID NOT CONSTITUTE THEINVESTING PUBLIC FOR PURPOSES OF COMPLETING A BONA FIDE PUBLICDISTRIBUTION OF SUCH SECURITIES. THE CUSTOMERS WEREPREDOMINATELY ACCOUNTS FOR WHICH EITHER RESPONDENT PORUSH ORTHE FIRMS PRIOR CHIEF EXECUTIVE OFFICER, WERE THE ACCOUNTEXECUTIVES. IN EACH OF THE OFFERINGS, RESPONDENT PORUSH RECEIVEDTHE LARGEST IPO ALLOCATION AT RESPONDENT MEMBER. THE PRIOR CHIEFEXECUTIVE OFFICER RECEIVED THE SECOND LARGEST ALLOCATION ATRESPONDENT MEMBER. BEFORE THE OPENING OF THE MARKET FOR EACH OFTHE FIVE OFFERINGS, RESPONDENT PORUSH, DIRECTLY, OR WITH THEASSISTANCE OF OTHERS, PREPARED SELL ORDER TICKETS FOR CUSTOMERACCOUNTS TO SELL THE UNITS OF THE OFFERING BACK TO RESPONDENTMEMBER THAT HAD BEEN SOLD TO THEM. SELL ORDERS FOR SOME OF THECUSTOMERS WERE ARRANGED BY RESPONDENT PORUSH OR HISASSISTANTS AT THE SAME TIME THAT THE FIRM CONFIRMED INDICATIONS OFINTEREST FOR THE CUSTOMERS TO BUY IN THE OFFERING. THESE SELLORDERS FROM THE CUSTOMERS WERE ENTERED INTO THE FIRMS TRADINGSYSTEM PRIOR TO THE START OF AFTERMARKET TRADING IN EACH OF THEFIVE IPOs. IN EACH OF THE FIVE OFFERINGS, RESPONDENT SANDERSEXECUTED THESE SELL ORDERS AT A PREMIUM OF APPROXIMATELY $.375 TO$2 ABOVE THE PUBLIC OFFERING PRICE OF $4 IMMEDIATELY AT THECOMMENCEMENT OF AFTERMARKET TRADING OR WITHIN THE FIRST SEVENMINUTES OF AFTERMARKET TRADING. THE PATTERN BY THESE CUSTOMERSOF SELLING IMMEDIATELY AT THOSE PREMIUMS OCCURRED DESPITE THEFACT THAT THE PRICE OF THE UNITS INCREASED TO $8 - $9 , DOUBLE THEPUBLIC OFFERING PRICE OR HIGHER, WITHIN FOUR MINUTES OF THEOPENING OF TRADING FOR EACH OF FIVE OFFERINGS. AS A CONSEQUENCEOF THIS PREARRANGEMENT WITH THE CUSTOMERS, RESPONDENT MEMBER,



ACTING THROUGH RESPONDENTS PORUSH AND SANDERS, PURCHASED 41 TO55 PERCENT OF RESPONDENT MEMBERS ALLOCATION FROM THECUSTOMERS WITHIN THE FIRST SEVEN MINUTES OF AFTERMARKET TRADING.THE SECURITIES THAT THE CUSTOMERS SOLD TO RESPONDENT MEMBER INTHE IMMEDIATE AFTERMARKET WERE PURCHASED BY RESPONDENTMEMBER, THROUGH RESPONDENT SANDERS, INTO THE FIRMS PRIOPRIETARYACCOUNT. THESE SECURITIES WERE THEN USED TO COVER THE FIRMS SALEOF THE COMPONENTS OF THE UNIT OFFERING TO RETAIL CUSTOMER IN THEIMMEDIATE AFTERMARKET. FOR EACH OF THE FIVE OFFERINGS, RESPONDENTMEMBER, ACTING THROUGH RESPONDENT PORUSH AND OTHERS, EITHERDIRECTLY OR THROUGH ASSOCIATED PERSONS ACTING AT THE DIRECTIONOF RESPONDENTS MEMBER AND PORUSH, SOLICITED CUSTOMERS PRIOR TOTHE EFFECTIVE DATE OF THE OFFERING, TO PURCHASE SECURITIES OF THEISSUER IN AFTERMARKET TRADING. PRIOR TO THE CLOSE OF THE FIVEOFFERINGS, RESPONDENT MEMBER INFORMED NUMEROUS RETAILCUSTOMERS, OTHER THAN CUSTOMERS OF RESPONDENT PORUSH AND THEPRIOR CHEIF EXECUTIVE OFFICER, THAT CUSTOMERS WERE REQUIRED TOCOMMIT TO PURCHASE COMMON STOCK OR WARRANTS IN THEAFTERMARKET IN ORDER TO PURCHASE IN THE UNDERWRITING. AS A RESULTOF SUCH CONDITIONING OF IPO ALLOCATIONS TO CUSTOMERS DURING THEIPOs, THE CUSTOMERS WHO PURCHASED UNITS IN THE FIVE OFFERINGSACCOUNTED FOR 83 TO 95 PERCENT OF ALL COMMON STOCK SOLD BYRESPONDENT MEMBER ON THE FIRST DAY OF AFTERMARKET TRADING. SUCHINSTRUCTIONS TO CUSTOMERS BY RESPONDENT MEMBER'S REGISTEREDREPRESENTATIVES CONSTITUTED MISREPRESENTATIONS OF MATERIAL FACTRELATING TO THE TERMS OF EACH OF THE OFFERINGS, AND OF THECUSTOMERS TRUE OBLIGATIONS UNDER THE FEDERAL SECURITIES LAWS.REQUIRING CUSTOMERS TO ENTER INTO SUCH AN AGREEMENT CONSTITUTESMANIPULATIVE, DECEPTIVE, AND FRAUDULENT ACTS. THE MANIPULATIVE,DECEPTIVE AND FRAUDULENT ACTIONS BY RESPONDENT MEMBER, THROUGHRESPONDENTS PORUSH AND SANDERS CONSTITUTED AN INTENTIONALINTERFERENCE WITH THE FREE FORCES OF SUPPLY AND DEMAND FOR THESECURITIES OF EACH OF THESE ISSUERS. RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENTS PORUSH, SANDERS, STITSKY, AND SHAMAH,ENGAGED IN, AND INDUCED OTHERS TO ENGAGE IN: A) THE USE OF AMANIPULATIVE AND FRAUDULENT SCHEME TO DEFRAUD; AND B) THE BIDDINGFOR OR PURCHASING FOR A PROPRIETARY ACCOUNT OF RESPONDENTMEMBER OF STEVEN MADDEN COMMON STOCK PRIOR TO RESPONDENTMEMBERS COMPLETION OF ITS PARTICIPATION IN THE DISTRIBUTION OF SUCHSECURITIES FROM THE SELLING SECURITYHOLDERS; RESPONDENT MEMBER,ACTING THROUGH RESPONDENTS PORUSH, STITSKY, AND SHAMAH,



DIRECTLY, OR INDIRECTLY SOLICITED CUSTOMERS TO PURCHASE STEVENMADDEN COMMON STOCK THAT WAS TO BE SOLD BY SELLINGSECURITYHOLDERS; RESPONDENT MEMBER, ACTING THROUGHRESPONDENTS PORUSH, SANDERS, STITSKY AND SHAMAH, PLACED 30PERCENT OF THE SHARES BEING SOLD BY SELLING SECURITYHOLDERS INTOCUSTOMER ACCOUNTS THAT THEY PREARRANGED TO HAVE SELL ORREASONABLY BELIEVED WOULD SELL ITS SHARES TO RESPONDENT MEMBERAT A SMALL, PREDETERMINED PROFIT IN THE IMMEDIATE AFTERMARKETTRADING OF THE SECURITY; SINCE RESPONDENT MEMBER, ACTING THROUGHRESPONDENTS PORUSH, SANDERS, STITSKY, AND SHAMAH PREARRANGEDTO SELL OR REASONABLY BELIEVED THAT THESE CUSTOMERS WERE GOINGTO SELL THEIR STEVEN MADDEN COMMON STOCK IN THE IMMEDIATEAFTERMARKET TO RESPONDENT MEMBER AT PREDETERMINED PRICES,THESE CUSTOMERS DID NOT CONSTITUTE THE INVESTING PUBLIC FORPURPOSES OF COMPLETING A BONA FIDE PUBLIC DISTRIBUTION OF SUCHSECURITIES BY RESPONDENTS MEMBER, PORUSH, SANDERS, STITSKY ANDSHAMAH; RESPONDENT MEMBER, ACTING THROUGH RESPONDENT SANDERS,PURCHASE 332,304 SHARES OF STEVEN MADDEN COMMON STOCK FROMCUSTOMERS WITHIN THE FIRST MINUTE OF THE OPEN OF TRADING AT$5/SHARE, A $1 PREMIUM TO THE PRICE IN WHICH IT WAS SOLD TO THEM;RESPONDENT MEMBER PURCHASED STEVEN MADDEN COMMON STOCK ON APROPRIETARY BASIS FROM CUSTOMERS AND THEREAFTER SOLD THOSESHARES TO PUBLIC CUSTOMERS AT SIGNIFICANTLY HIGHER PRICES;RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS PORUSH ANDSANDERS, ENGAGED IN MANIPULATIVE, DECEPTIVE AND OTHER FRAUDULENTDEVICES IN CONNECTION WITH STEVEN MADDEN COMMON STOCK. PRIOR TOTHE START OF AFTERMARKET TRADING IN STEVEN MADDEN COMMON STOCK,RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS PORUSH ANDSANDERS, ARRANGED FOR BOTH A SUPPLY AND DEMAND OF THE STOCK TOBE AVAILABLE TO RESPONDENT MEMBERS TRADING DEPARTMENT AT THETIME STEVEN MADDEN COMMON STOCK BEGAN AFTERMARKET TRADINGWHICH ALLOWED RESPONDENT MEMBER TO MANIPULATE THE SECURITYWHILE ENGAGING IN RISKLESS PRINCIPAL TRANSACTIONS; RESPONDENTMEMBER, ACTING THROUGH RESPONDENTS PORUSH AND SANDERS,ENGAGED IN THE PURCHASED SALE OF SECURITIES AT ARBITRARY PRICES,NOT RELATED TO PRICES SET BY THE MARKETS TRUE SUPPLY AND DEMAND;WHILE DOMINATING AND CONTROLLING STEVEN MADDEN COMMON STOCKAND POSITIONED TO ENGAGE IN SUCH ARBITRARY PRICING OF THE SECURITY,RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS PORUSH ANDSANDERS, UPTICKED THE INSIDE BID OF THE STEVEN MADDEN COMMONSTOCK SIX TIMES TO THE EXCLUSIVE HIGH BID. RESPONDENT MEMBERS



UPTICKED ITS OWN EXCLUSIVE INSIDE BID ON THREE OF THE SIX UPTICKS. ASA CONSEQUENCE, RESPONDENT MEMBER EITHER HAD THE EXCLUSIVE HIGHBID OR SHARED THE HIGH BID FOR 99.4 PERCENT OF THE MARKET TIME ANDRESULTED IN ILLEGAL PROFITS OF $5.2 MILLON; RESPONDENT MEMBER,ACTING THROUGH RESPONDENT SANDERS, EFFECTED TRANSACTIONS IN,AND INDUCED OTHERS TO EFFECT TRANSACTIONS IN A STEVEN MADDENWARRANTS AT PRICES WHICH WERE UNFAIR IN THAT THEY WERE NOTREASONABLY RELATED TO THE PREVAILING MARKET PRICE OF THOSESECURITIES; ENGAGED IN, AND INDUCED OTHERS TO ENGAGE IN,FRAUDULENT AND DECEPTIVE DEVICES AND CONTRIVANCES IN CONNECTIONWITH THE CHARGING OF EXCESSIVE MARKUPS IN THE SALE OF STEVENMADDEN WARRANTS; FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIALHONOR, AND JUST AND EQUITABLE PRINCIPLES OF TRADE IN CONNECTIONWITH THE FIRMS SALES OF STEVEN MADDEN WARRANTS TO ITS CUSTOMERSAT UNFAIR AND FRAUDULENTLY EXCESSIVE PRICES; DOMINATED ANDCONTROLLED THE MARKET FOR STEVEN MADDEN WARRANTS SUCH THATTHERE WERE NO INDEPENDENT, COMPETITIVE MARKET IN THOSESECURITIES; CHARGED ITS RETAIL CUSTOMERS FRAUDULENTLY EXCESSIVEMARKUPS IN 41 TRANSACTIONS WHICH RANGED FROM 10 TO 71.43 PERCENTOVER THE PREVAILING MARKET PRICE; RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENT PORUSH, ALLOCIATED UNITS IN FIVE OFFERINGS TOCUSTOMERS WHO WERE RESTRICTED FROM PURCHASING SUCH SECURITIESAT RESPONDENT MEMBER PURSUANT TO THE NASD FREE-RIDING ANDWITHHOLDING INTERPRETATION; RESPONDENTS MEMBER, PORUSH ANDSTITSKY FAILED TO ADEQUATELY SUPERVISE THE FIRMS TRADING ACTIVITY,SPECIFICALLY WITH RESPECT TO THE FIRMS FAILURE TO COMPLETE BONAFIDE DISTRIBUTIONS OF SECURITIES, THE MANIPULATION OF SECURITIES,AND THE CHARGING OF FRAUDULENTLY EXCESSIVE MARKUPS, AND FAILEDTO SUPERVISE THE RETAIL SALES FORCE IN THEIR MAKING MATERIALMISREPRESENTATIONS AND OMISSIONS TO CUSTOMERS AND THE SALE OFHOT ISSUE OFFERINGS TO RESTRICTED ACCOUNTS; AND, RESPONDENTSMEMBER AND PORUSH, FAILED TO ESTABLISH AND MAINTAIN REASONABLESUPERVISORY PROCEDURES TO PREVENT THE FIRM'S VIOLATIVE CONDUCT.ON JULY 8, 1998, THE DECISION AND ORDER OF ACCEPTANCE OF OFFER OFSETTLEMENT SUBMITTED BY RESPONDENT STRATTON OAKMONT, INC. WASISSUED; THEREFORE, RESPONDENT MEMBER IS EXPELLED FROM NASDMEMBERSHIP.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10960068 FILED JUNE 6, 1996 BY DISTRICT NO. 10 STRATTONOAKMONT, INC. AND PATRICK GERARD HAYES ALLEGING VIOLATIONS OFARTICLE III, SECTIONS 1, 27 AND 50 OF THE RULES OF FAIR PRACTICE IN THATRESPONDENT MEMBER, ACTING THROUGH RESPONDENT HAYES, FAILED TOREPORT, OR OTHERWISE INFORM THE NASD OF STATISTICAL AND SUMMARY



INFORMATION REGARDING 59 CUSTOMER COMPLAINTS THE FIRM RECEIVEDDURING THE RELEVANT TIME PERIOD AS REQUIRED; AND, FAILED TOESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES DESIGNED TOINSURE THAT THE FIRM COMPLIED WITH THE REQUIREMENTS OF ARTICLE III,SECTION 50. DECISION RENDERED FEBRUARY 3, 1997, WHEREINRESPONDENT MEMBER IS CENSURED, FINED $50,000 AND ASSESSED COSTSOF $2,262.25; AND, RESPONDENT HAYES IS FINED $500, REQUIRED TOREQUALIFY BY EXAMINATION IN ALL CAPACITIES PRIOR TO REASSOCIATINGWITH A MEMBER FIRM, AND ASSESSED HEARING COSTS OF $100. IF NOFURTHER ACTION, DECISION IS FINAL MARCH 20, 1997. MARCH 20, 1997 -DECISION IS FINAL.



Regulatory - Final


Disclosure



Allegations: REVOCATION PURSUANT TO AN SEC ORDER ENJOINING STRATTONPERMANENTLY FROM CERTAIN CONDUCT IN THE SECURITIES BUSINESS;REVOCATION PURSUANT TO SUSPENSION ORDERS OF ALABAMA AND INDIANAAND REVOCATION PURSUANT TO SUSPENSION OF AN OFFICER ANDDIRECTOR BY THE NASD.

Initiated By: ILLINOIS SECURITIES DEPARTMENT

Date Initiated:

Docket/Case Number: 9600026





Resolution: ORDER


Sanctions Ordered:


Sanction Details: NOTICE OF HEARING ISSUED MAY 2, 1996. HEARING SET AUGUST 21, 1996.



CONSENT ORDER OF REVOCATION ISSUED DECEMBER 5, 1996. STRATTONWAS REVOKED AND FINED $10,000 AND $90,000 FOR COST OF INVESTIGATION.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:





Resolution: ACCEPTANCE, WAIVER AND CONSENT (AWC)


Sanctions Ordered:


Sanction Details: ON APRIL 1, 1996, DISTRICT NO. 10 NOTIFIED STRATTON OAKMONT, INC. ANDSTEVEN P. SANDERS THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C10960014 WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED, FINED $325,000, AND THE FILING OF WRITTENSUPERVISORY PROCEDURES WITHIN 10 DAYS OF FINAL NBCC APPROVAL OF



THE AWC (A) RELATING TO THE CONDUCT OF ASSOCIATED PERSONS DURINGAND PRECEDING AN IPO AIMED AT PREVENTING VIOLATIONS OF SECTION 5 OFTHE SECURITIES ACT OF 1933 AND RULE 10b-6 PROMULGATED UNDERSECTION 10(b) OF THE SECURITIES EXCHANGE ACT OF 1934; (B) AIMED ATPREVENTING SEC RULE 10b-10 VIOLATIONS; AND (C) AIMED AT PREVENTINGTHE TYPE OF ARBITRARY PRICING WHICH OCCURRED IN CONNECTION WITHTHE TRADING OF INITIAL PUBLIC OFFERINGS. RESPONDENT SANDERS WASCENSURED, FINED $50,000, SUSPENDED FROM ASSOCIATION WITH ANY NASDMEMBER IN ANY CAPACITY FOR 45 DAYS, AND AT THE CONCLUSION OF THESUSPENSION, RESPONDENT SANDERS UNDERTAKES FOR 5 DAYS NOT TOENGAGE DIRECTLY OR INDIRECTLY IN ANY TRADING RELATED ACTIVITIES FORANY MEMBER FIRM, INCLUDING, BUT NOT LIMITED TO, NOT ACTING, DIRECTLYOR INDIRECTLY, AS A TRADER OR PERFORMING ANY TRADING RELATEDFUNCTIONS OR TO ADVISE ANYONE WITH RESPECT TO THE PREFORMANCEOF ANY SUCH FUNCTIONS. - (ARTICLE III, SECTIONS 1, 18, AND 27 OF THERULES OF FAIR PRACTICE - IN CONNECTION WITH THE SALE OFUNREGISTERED SECURITIES IN AN INITIAL PUBLIC OFFERING, RESPONDENTMEMBER ACCEPTED PAYMENT AND THEREBY EFFECTED SALES IN THEOFFERING BEFORE THE REGISTRATION STATEMENT FOR THE OFFERING WASDECLARED EFFECTIVE BY THE SEC; RESPONDENTS MEMBER AND SANDERSVIOLATED SECTION 10(b) OF THE SECURITIES EXCHANGE ACT OF 1934 ANDRULE 10b-6 THEREUNDER IN CONNECTION WITH AN INITIAL PUBLIC OFFERINGIN THAT BEFORE RESPONDENT MEMBER COMPLETED ITS ROLE IN THEDISTRIBUTION, IT BID FOR THE PURCHASE OF SECURITIES SUBJECT TO THEDISTRIBUTION AND RESPONDENT SANDERS EXECUTED THE TRADES THEREBYFAILING TO COMPLY WITH THE TRADING RESTRICTIONS APPLICABLE TO THEDISTRIBUTION OF SECURITIES; RESPONDENT MEMBER, ACTING THROUGHSANDERS, PURCHASED SECURITIES IN AN INITIAL PUBLIC OFFERING FROM ITSCUSTOMERS AT ARBITRARY PRICES IN VIOLATION OF SECTION 10(b) OF THESECURITIES EXCHAGNE ACT OF 1934 AND RULE 10b-5 THEREUNDER BYPURCHASING WARRANTS TO A RISING MARKET FROM CUSTOMERS AT PRICESLOWER THAN THOSE GIVEN TO CUSTOMERS WHO PLACED EARLIER ORDERS;FAILED TO NOTIFY CUSTOMERS OF RESPONDENT MEMBER'S MARKET MAKERSTATUS AND TO PROVIDE SUCH INFORMATION ON CONFIRMATIONS INVIOLATION OF SECTION 10(b) OF THE SECURITIES EXCHANGE ACT OF 1934AND RULE 10b-10 THEREUNDER; AND, FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES). ***$325,000.00PAID AS OF 04/15/96, INVOICE #96-10-282***



Regulatory - Final


Disclosure



Allegations: Allegations of fraudulent sales practices, policies and procedures in the District ofColumbia.

Initiated By: DISTRICT OF COLUMBIA

Date Initiated:

Docket/Case Number: 949-C 2





Resolution: ORDER


Sanctions Ordered:


Sanction Details: By Order # 949-C dated 2/26/96, the Securities Division of the Public ServiceCommission of the District of Columbia summarily suspended Stratton Oakmont, Inc. totransact securities business pending the outcome of an investigation. Pursuant to theD.C. Code 2-2609 (a) (1) (D) and (F) summarily suspends the broker/dealer license of



Stratton Oakmont, Inc. and opens an investigation into the sales practices, polices andprocedures of the firm.



Regulatory - Final


Disclosure



Allegations: ON 2/21/96, THE INDIANA SECURITIES COMMISSIONER ORDERED THESUSPENSION OF STRATTON OAKMONT'S INDIANA BROKER-DEALERREGISTRATION FOR A PERIOD OF THREE YEARS FROM THE DATE OF THEORDER. IT WAS FURTHER ORDERED THAT THE COSTS OF THEADMINISTRATIVE PROCEEDING, TOTALING $1,092.79, BE ASSESSED AGAINSTSTRATTON OAKMONT, INC. SAID COSTS ARE TO BE PAID WITHIN THIRTY DAYSOF THE DATE OF SERVICE.

Initiated By: INDIANA

Date Initiated:

Docket/Case Number: 95-0025 SO





Resolution: ORDER


Sanctions Ordered:




Sanction Details:



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10950081 FILED OCTOBER 5, 1995 BY DISTRICT NO. 10AGAINST STRATTON OAKMONT, INC., STEVEN P. SANDERS, DANIEL M. PORUSHAND PAUL F. BYRNE ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 14, 18AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT MEMBER,ACTING THROUGH RESPONDENT SANDERS, EFFECTED TRANSACTIONS IN, AND



INDUCED OTHERS TO EFFECT TRANSACTIONS IN STOCK AT PRICES THATWERE UNFAIR IN THAT THEY WERE NOT REASONABLY RELATED TO THEPREVAILING MARKET PRICE OF THOSE SECURITIES; ENGAGED IN, ANDINDUCED OTHERS TO ENGAGE IN, FRAUDULENT AND DECEPTIVE DEVICES ANDCONTRIVANCES IN CONNECTION WITH THE CHARGING OF EXCESSIVEMARKUPS IN THE SALE OF STOCK; FAILED TO OBSERVE HIGH STANDARDS OFCOMMERCIAL HONOR, AND JUST AND EQUITABLE PRINCIPLES OF TRADE INCONNECTIONS WITH THE FIRM'S SALES OF STOCK TO ITS CUSTOMERS ATUNFAIR AND FRAUDULENTLY EXCESSIVE PRICES; DOMINATED ANDCONTROLLED THE MARKET FOR THE SECURITIES SUCH THAT THERE WAS NOINDEPENDENT, COMPETITIVE MARKET IN THOSE SECURITIES; CHARGED ITSRETAIL CUSTOMERS FRAUDLENTLY EXCESSIVE MARKUPS RANGING FROM5.56 TO 33.33 PERCENT OVERTHE PREVAILING MARKET PRICE; RESPONDENTSMEMBER, PORUSH AND BYRNE FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE REASONABLE SUPERVISORY PROCEDURES TO PREVENT THE FIRM'SRETAIL CUSTOMERS FROM BEING CHARGED EXCESSIVE AND FRAUDULENTLYEXCESSIVE MARKUPS IN PURCHASES. DECISION RENDERED APRIL 15, 1996,WHEREIN RESPONDENT MEMBER IS CENSURED, FINED $500,000, REQUIRED TODISGORGE ITS EXCESS PROFITS TOTALING $1,876,205 TO ITS CUSTOMERS,PLUS PREJUDGMENT INTEREST, AND SUSPENDED FROM EFFECTING ANYPRINCIPAL RETAIL TRANSACTIONS FOR ONE YEAR; RESPONDENT SANDERS ISCENSURED, FINED $25,000, SUSPENDED FROM ASSOCIATION WITH ANY NASDMEMBER IN ANY CAPACITY FOR ONE YEAR, AND AT THE END OF THESUSPENSION, REQUIRED TO REQUALIFY AS A GENERAL SECURITIESREPRESENTATIVE AND A GENERAL SECURITIES PRINCIPAL; RESPONDENTPORUSH IS CENSURED, FINED $250,000 AND BARRED FROM ASSOCIATIONWITH ANY NASD MEMBER IN ANY CAPACITY; AND, RESPONDENTS MEMBER,SANDERS AND PORUSH ARE ASSESSED COSTS OF $4,810, JOINTLY ANDSEVERALLY. THE DBCC DISMISSED THE COMPLAINT AS TO RESPONDENTBYRNE FOR LACK OF CONCLUSIVE EVIDENCE THAT HE WAS RESPONSIBLE FORTHE VIOLATIONS. IF NO FURTHER ACTION, DECISION IS FINAL MAY 30, 1996.APRIL 29, 1996 - APPEALED TO THE NBCC BY RESPONDENTS MEMBER,SANDER AND PORUSH. NBCC DECISION RENDERED DECEMBER 5, 1996,WHEREIN THE FINDINGS MADE ARE AFFIRMED AND THE SANCTIONS IMPOSEDARE MODIFIED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED$500,000, EXPELLED FROM NASD MEMBERSHIP, AND, REQUIRED TO PAY$416,528.77 IN RESTITUTION; RESPONDENT PORUSH IS CENSURED, FINED$250,000 AND BARRED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANYCAPACITY; RESPONDENT SANDERS IS CENSURED, FINED $25,000 AND BARREDFROM ASOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY; AND,RESPONDENTS MEMBER, PORUSH, AND SANDERS ARE ASSESSED DBCC



COSTS OF $4,810, JOINTLY AND SEVERALLY AND NBCC COSTS OF $750,JOINTLY AND SEVERALLY. IF NO FURTHER ACTION, DECISION IS FINALJANUARY 6, 1997. **************************************************************** 12-11-96,SEC NEWS DIGEST ISSUE NO. 96-233, DATED DECEMBER 9, 1996,ENFORCEMENT PROCEEDINGS DISCLOSE: "COMMISSION DENIES STAYREQUESTS BY STRATTON OAKMONT AND ITS PRESIDENT, BUT DELAYSEXPULSION OF FIRM FOR ONE WEEK"; THE COMMISSION HAS DENIEDREQUESTS BY STRATTON OAKMONT, INC., OF LAKE SUCCESS, NEW YORK(STRATTON) AND ITS PRESIDENT, DANIEL M. PORUSH OF BAYSIDE, NEW YORK,FOR STAYS OF THE SANCTIONS IMPOSED IN A DECEMBER 5, 1996 DECISIONOF THE NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. (NASD). THENASD FOUND THAT STRATTON CHARGED FRAUDULENT AND EXCESSIVEPRICES IN THE SALE OF WARRANTS OF MASTER GLAZIER'S KARATEINTERNATIONAL, INC., IN VIOLATION OF NASD RULES, AND THAT PORUSH WASRESPONSIBLE FOR SUPERVISORY FAILINGS IN CONNECTION WITH THESEVIOLATIONS. AMONG OTHER SANCTIONS THAT IT IMPOSED, THE NASDEXPELLED STRATTON FROM NASD MEMBERSHIP AND BARRED PORUSH FROMASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY. THE COMMISSIONDENIED THE STAY REQUESTS BASED UPON THE SERIOUSNESS OF THEMISCONDUCT AND ON THE APPLICANTS' FAILURE TO PRESENT COMPELLINGJUSTIFICATION FOR SUCH RELIEF. THE COMMISSION DETERMINED TO ALLOWSTRATTON TO REMAIN IN OPERATION FOR FIVE BUSINESS DAYS AFTER THEDATE OF THE COMMISSION'S ORDER, SOLELY TO THE EXTENT THAT STRATTONMAY EFFECT ON BEHALF OF ITS CUSTOMERS UNSOLICITED LIQUIDATINGTRANSACTIONS, ON AN AGENCY BASIS. (REL. 34-38026) JANUARY 6, 1997 -DECISION IS FINAL.



Regulatory - Final


Disclosure



Allegations: RESPONDENT, STRATTON OAKMONT, INC., FAILED TO PROVIDE DOCUMENTSFORMALLY REQUESTED PURSUANT TO THE DIVISION'S AUTHORITY UNDER NRS90.410.

Initiated By: NEVADA SECRETARY OF STATE, SECURITIES DIVISION

Date Initiated:

Docket/Case Number: I94-108





Resolution: ORDER


Sanctions Ordered:


Sanction Details: A SUMMARY ORDER WITH NOTICE OF OPPORTUNITY FOR HEARING WASISSUED AGAINST RESPONDENT, STRATTON OAKMONT, INC. ON AUGUST 3,1995. THE FIRM WAS SUSPENDED UNTIL SUCH TIME AS IT COMPLIED WITH THE



FORMAL WRITTEN REQUESTS FOR DOCUMENTS.

AN ORDER LIFTING THE SUMMARY ORDER OF SUSPENSION OF THE BROKER-DEALER LICENSE OF STRATTON OAKMONT, INC. IN THE STATE OF NEVADAWAS SIGNED BY THE ADMINISTRATOR ON 8/7/95. STRATTON OAKMONT, INC.COMPLIED WITH THE FORMAL WRITTEN REQUESTS FOR INFORMATION, ANDCERTAIN OTHER UNDERTAKINGS. THE SUSPENSION WAS LIFTED AS OF THEOPENING OF THE MARKET (NEW YORK STOCK EXCHANGE) ON 8/8/95.

THE NEVADA SECURITIES DIVISION'S SUMMARY ORDER SUSPENDING THEBROKER- DEALER LICENSE OF STRATTON OAKMONT, INC. IN THE STATE OFNEVADA HAS BEEN LIFTED AS OF 8/8/95.



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Disclosure



Allegations: UNAUTHORIZED TRANSACTIONS AND FAILURE TO REPORT SETTLEMENTS TOTHE CRD.


Date Initiated:






Resolution: ORDER


Sanctions Ordered:


Sanction Details: STRATTON OAKMONT, INC. ENTERED INTO A CONSENT ORDER WHEREBY ITWAS FINED $5,000 AND PAID $57,425 IN RESTITUTION TO THE CLIENT.



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Disclosure



Allegations: ORDER OF SUSPENSION

Initiated By: STATE OF GEORGIA

Date Initiated:






Resolution: ORDER


Sanctions Ordered:


Sanction Details: REGISTRATION OF STRATTON OAKMONT SUSPENDED IN THE STATE OFGEORGIA EFFECTIVE JUNE 19, 1995.

ON JUNE 19, 1995 THE COMMISSIONER OF SECURITIES OF THE STATE OFGEORGIA SUSPENDED THE REGISTRATION OF STRATTON OAKMONT IN THISSTATE BASED ON THE PERMANENT INJUNCTION ISSUED BY THE UNITED



STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA.



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Disclosure



Allegations:

Initiated By: SECURITIES AND EXCHANGE COMMISSION

Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: +4/4/94 SEC NEWS DIGEST, ISSUE 94-56 DATED MARCH 25, 1994 ENFORCEMENTPROCEEDINGS DISCLOSES; "SETTLEMENT REACHED WITH STRATTONOAKMONT, INC. JORDAN BELFORT, KENNETH GREENE AND DANIEL PORUSH";THE COMMISSION ACCEPTED THE OFFERS OF SETTLEMENT OF STRATTONOAKMONT, INC., JORDON BELFORT, KENNETH GREENE AND DANIEL PORUSH.



STRATTON CONSENTED TO AN ORDER THAT CENSURES STRATTON ANDORDERS IT TO COMPLY WITH CERTAIN REMEDIAL UNDERTAKINGS. BELFORTCONSENTED TO AN ORDER THAT BARS HIM FROM ASSOCIATION WITH CERTAINCOMMISSION REGULATED ENTITIES. GREENE CONSENTED TO AN ORDER THATBARS HIM FROM ASSOCIATION WITH CERTAIN REGULATED ENTITIES WITH ARIGHT TO REAPPLY AFTER FIVE YEARS. PORUSH CONSENTED TO AN ORDERTHAT SUSPENDS HIM FROM ASSOCIATION IN A SUPERVISORY CAPACITY WITHCERTAIN COMMISSION REGULATED ENTITIES FOR A PERIOD OF 12 MONTHSAND ORDERS HIM TO PAY A PENALTY OF $100,000. (REL 34-3378) ^11/16/94SEC DOCKET, VOLUME 56, NO. 6, DATED APRIL 5, 1994, PAGE 822, DISCLOSES;ORDER OF CENSURE AGAINST RESPONDENT STRATTON IS DATED MARCH 17,1994. THIS ORDER ALSO REQUIRES THAT STRATTON RETAIN AN INDEPENDENTCONSULTANT TO UNDERTAKE A REVIEW OF ALL OF STRATTON'S POLICIES,PRACTICES AND PROCEDURES, WHICH AFORESAID POLICIES SHALL BEADOPTED, IMPLEMENTED AND MAINTAINED BY STRATTON. AN INDEPENDENTAUDITOR SHALL ALSO BE RETAINED TO CONDUCT 4 SPECIAL REVIEWS OFSAID POLICIES.



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Disclosure



Allegations: ORDER TO SHOW CAUSE ALLEGES THAT IT IS IN THE PUBLIC INTEREST FORTHE PENNSYLVANIA SECURITIES COMMISSION TO DENY, SUSPEND ORREVOKE STRATTON'S BROKER-DEALER REGISTRATION IN PENNSYLVANIABASED UPON A JANUARY 11, 1995 PRELIMINARY INJUNCTION AND FEBRUARY28, 1995 PERMANENT INJUNCTION ISSUED BY THE U.S. DISTRICT COURT FORTHE DISTRICT OF COLUMBIA AGAINST STRATTON. THE ORDER ALSO ALLEGESTHAT STRATTON HAS ENGAGED IN DISHONEST AND/OR UNETHICAL BUSINESSPRACTICES BY REPEATEDLY FAILING TO COMPLY WITH THE SEC MARCH 17,1994 ORDER AND THE DISTRICT COURT'S DECEMBER 19, 1994 TEMPORARYRESTRAINING ORDER AND JANUARY 11, 1995 PRELIMINARY INJUNCTION, ALLOF WHICH WERE DESIGNED TO PROTECT THE INVESTING PUBLIC.

VIOLATION OF REGULATION 305.019(b).

Initiated By: PENNSYLVANIA SECURITIES COMMISSION

Date Initiated:

Docket/Case Number: 9505-01LC







Resolution: REVOCATION


Sanctions Ordered:


Sanction Details: ORDER TO SHOW CAUSE ISSUED TO RESPONDENT.

STRATTON OAKMONT'S REGISTRATION IN PENNSYLVANIA IS REVOKED. 10.Summary: STRATTON ENGAGED IN DISHONEST AND/OR UNETHICAL BUSINESSPRACTICES IN THE SECURITIES BUSINESS.



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Disclosure



Allegations: ON MAY 12, 1995 THE MASSACHUSETTS SECURITIES DIVISION FILED ANADMINISTRATIVE COMPLAINT TO REVOKE THE BROKER-DEALERREGISTRATION OF STRATTON OAKMONT, INC. PURSUANT TO M.G.L. c.110ASECTION 204(a)(2)(D). AS A RESULT OF THE U.S. DISTRICT COURT (D.C.)'S TROOF DECEMBER 19, 1994, PRELIMINARY INJUNCTION OF JANUARY 11, 1995 ANDPERMANENET INJUNCTION OF FEBRUARY 28, 1995.

Initiated By: MASSACHUSETTS SECURITIES DIVISION

Date Initiated:

Docket/Case Number: R-95-081





Resolution: ORDER


Sanctions Ordered:




Sanction Details: ON NOVEMBER 13, 1995, THE DIVISION ENTERED A CONSENT ORDER IN THEMATTER OF STRATTON OAKMONT, INC. - DOCKET NO. R-95-081. STRATTONSUBMITTED A SIGNED OFFER OF SETTLEMENT WHICH CONTAINEDUNDERTAKINGS AND REPRESENTATIONS AND IN WHICH STRATTONCONSENTED TO THE ENTRY OF A CONSENT ORDER. IN ACCORDANCE WITHTHE TERMS OF THE AGREEMENT, STRATTON WITHDREW ITS REGISTRATIONAS A BROKER-DEALR IN MASSACHUSETTS AND PAID ADMINISTRATIVE COSTSOF $15,000. THE DIVISION ALSO ESTABLISHED A FUND TO PROVIDE INVESTOREDUCATION FOR MASSACHUSETTS INVESTORS WITH THE SUME OF $60,000RECEIVED BY STRATTON. THE AGREEMENT ALSO REQUIRED THAT STRATTONMUST NOTIFY ALL PRESENT AND FUTURE MASSACHUSETTS COMPLAINANTSOF THE AVAILABILITY OF ARBITRATION AND DISPUTES AGAINST STRATTONAND A LIST OF NAMES AND ADDRESSES OF AVAILABLE ARBITRATIONAGENCIES.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:





Resolution: ORDER


Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10950032 FILED APRIL 26, 1995 BY DISTRICT NO. 10 AGAINSTSTRATTON OAKMONT, INC. ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE AND SCHEDULE C OF THE NASD BY-LAWS INTHAT RESPONDENT MEMBER VIOLATED A RESTRICTION IMPOSED BY THEPRE-MEMBERSHIP INTERVIEW SUBCOMMITTEE THAT IT HOLD THE NUMBER OF



REGISTERED REPRESENTATIVES AT 217 PENDING COMPLETION OF THE PRE-MEMBERSHIP INTERVIEW PROCESS. ON NOVEMBER 20, 1995, THE DECISIONAND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BYRESPONDENT MEMBER WAS ISSUED; THEREFORE, RESPONDENT MEMBER ISCENSURED AND FINED $7,500. ***************************************************************$7,500.00 PAID ON 12/19/95, INVOICE #95-10-763****



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Disclosure



Allegations: ON DECEMBER 29, 1994, THE NEBRASKA DEPARTMENT OF BANKING ANDFINANCE ENTERED AN ORDER LIMITING THE BROKER DEALER LICENSE OFSTRATTON OAKMONT, INC., BASED ON A FINDING THAT STRATTON OAKMONTHAD NOT COMPLIED WITH THE TERMS OF A WRITTEN UNDERTAKING DATEDJUNE 14, 1994. THE UNDERTAKING STIPULATED THAT STRATTON OAKMONTWOULD CEASE SUBSTANTIALLY ALL BROKER DEALER ACTIVITY IN NEBRASKAPENDING THE OUTCOME OF A DEPARTMENTAL INVESTIGATION INTO POSSIBLESECURITIES VIOLATIONS BY STRATTON OAKMONT.

Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE

Date Initiated:

Docket/Case Number:





Resolution: ORDER


Sanctions Ordered:




Sanction Details: THE ORDER LIMITS ACTIVITY BY STRATTON OAKMONT TO LIQUIDATIONS ANDIT ALLOWS NEBRASKA CUSTOMERS TO SELL OUT OF LONG POSITIONS ORPURCHASE SECURITIES TO COVER PREVIOUSLY TRANSACTED SHORT SALES.THE DEPARTMENTS INVESTIGATION OF POSSIBLE SECURITIES AND SALESPRACTICE VIOLATIONS IS ONGOING. CONTACT: RUSSELL K. BLOEMKER - (402)471-3445



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Disclosure



Allegations: VIOLATIONS OF THE VERMONT SECURITIES ACT IN CONNECTION WITH THE USDISTRICT COURT, DISTRICT OF COLUMBIA INJUNCTIVE ORDER AND OTHERSRO AND STATE REGULATORY ACTIONS. REQUEST HEARING. THE RIGHT TOREQUEST A HEARING EXPIRES MAY 1, 1995.

Initiated By: VERMONT SECURITIES DIVISION

Date Initiated:

Docket/Case Number: 95-025-S





Resolution: ORDER


Sanctions Ordered:


Sanction Details: THE DIVISION HAS FILED A NOTICE OF INTENT TO REVOKE BROKER-DEALERREGISTRATION AND NOTICE OF RIGHT TO REQUEST HEARING. THE RIGHT TO



REQUEST A HEARING EXPIRES MAY 1, 1995.

THE NOTICE IS FILED BASED UPON THE US DISTRICT COURT, DISTRICT OFCOLUMBIA, PERMANENT INJUNCTION ISSUED AGAINST RESPONDENT AND THEORDERS SUSPENDING RESPONDENT'S BROKER-DEALER REGISTRATIONISSUED BY THE STATES OF MISSISSIPPI, DELWARE, AND ALABAMA.



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Disclosure



Allegations: STRATTON OAKMONT, INC. AND ITS PRESIDENT, DANIEL M. PORUSH, ARE THESUBJECTS OF A PERMANENT INJUNCTION BY THE U.S. DISTRICT COURT FORTHE DISTRICT OF COLUMBIA, DATED MARCH 1, 1995. PURSUANT TO THATINJUNCTION, THE ALABAMA SECURITIES COMMISSION HAS SUSPENDEDRESPONDENTS' REGISTRATION.

ON MARCH 24, 1995, THE ALABAMA SECURITIES COMMISSION ISSUED ANORDER OF SUSPENSION (ADMINISTRATIVE ORDER OS-95-0026) TO STRATTONOAKMONT, INC., AND ITS PRESIDENT DANIEL M. PORUSH. BASED ONINFORMATION THAT THEY WERE SUBJECTS OF A PERMANENT COURTINJUNCTION BY THE U.S. DISTRICT COURT, WASHINGTON, D.C. ON JULY 10,1996, THE COMMISSION ISSUED A CONSENT ORDER (ADMINISTRATIVE ORDERCO-96-0039) BY WHICH THE REGISTRATION OF STRATTON OAKMONT INC., WASREVOKED FOR A PERIOD OF FIVE (5) YEARS. EXECUTION OF SAIDREVOCATION WAS SUSPENDED AND THE REGISTRATION OF STRATTONOAKMONT, INC. WAS IMMEDIATELY REINSTATED SUBJECT TO LIMITATIONSSPECIFIED IN THE ORDER.

Initiated By: ALABAMA SECURITIES

Date Initiated:

Docket/Case Number: OS95-0026 and CO-96-0039







Resolution: ORDER


Sanctions Ordered:


Sanction Details: SUSPENSION ORDER WAS ISSUED 3/24/95.

THE CONSENT ORDER RESOLVES OS-95-0026 AS IT PERTAINS TO STRATTON,HOWEVER OS-95-0026, AS IT PERTAINS TO DANIEL M. PORUSH, REMAINS INFULL FORCE AND EFFECT.



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Disclosure



Allegations: ON APRIL 3, 1995, THE INDIANA SECURITIES DIVISION ENTERED A SUMMARYORDER SUSPENDING THE BROKER-DEALER REGISTRATION OF STRATTONOAKMONT, INC., CRD #18692, BASED ON AN ADMINISTRATIVE COMPLAINTALLEGING THAT STRATTON OAKMONT (1) ENGAGED IN DISHONEST ANDUNETHICAL PRACTICES (2) HAS BEEN ENJOINED BY A COURT OF COMPETENTJURISDICTION (3) HAS BEEN THE SUBJECT OF A DETERMINATION BY THE SECTO HAVE WILLFULLY VIOLATED FEDERAL SECURITIES LAWS.

Initiated By: INDIANA SECURITIES DIVISION

Date Initiated:

Docket/Case Number: 95-0025 SO







Sanctions Ordered:




Sanction Details:



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Disclosure



Allegations: ON FEBRUARY 28, 1995 THE U.S. DISTRICT COURT FOR THE DISTRICT OFCOLUMBIA ISSUED AN OPINION AND ORDER WHICH PERMANENTLY ENJOINEDSTRATTON OAKMONT FROM VIOLATING A MARCH 17, 1995 SEC CONSENTORDER. THE SEC ORDER MADE FINDINGS THAT STRATTON OAKMONT HADENGAGED IN FRAUDULENT CONDUCT AND REQUIRED THAT STRATTONOAKMONT ADOPT CERTAIN POLICIES, PRACTICES, AND PROCEDURES TO BEESTABLISHED BY AN INDEPENDENT CONSULTANT. THE DISTRICT COURTFOUND, AMONG OTHER THINGS, THAT STRATTON OAKMONT DELIBERATELYDISREGARDED THE SEC ORDER, INTENTIONALLY DEFIED A TEMPORARYRESTRAINING ORDER ISSUED BY THE DISTRICT COURT DATED DECEMBER 19,1994, AND FAILED TO COMPLY WITH THE REQUIREMENTS OF A JANUARY 11,1995 DISTRICT COURT PRELIMINARY INJUNCTION. BASED UPON THESEALLEGATIONS, THE DELAWARE SECURITIES COMMISSIONER FOUND IT IN THEPUBLIC INTEREST TO SUMMARILY SUSPEND STRATTON OAKMONT'S BROKER-DEALER LICENSE PURSUANT TO 6 DEL. C. SECTION 7316 (a)(4), (a)(7) and (c).STRATTON OAKMONT HAS 30 DAYS TO REQUEST AN EXPEDITED HEARING.FOR FURTHER INFORMATION REGARDING THIS MATTER, CONTACT PETEJAMISON AT (302) 577-2515.

The Division of Securities commenced disciplinary action against Stratton Oakmont onthe grounds that (a) the United States District Court for the District of Columbia hadissued a permanent injunction against Stratton Oakmont relating to its securitiesbusiness; (b) Stratton Oakmont had engaged in dishonest and unethical behavior byfailing to comply with an S.E.C. administrative order, a U. S. District Court temporary re-straining order, and a U. S. District Court preliminary injunction; and (c) StrattonOakmont failed reasonably to supervise an agent who was executing unauthorized



transactions in a customer's account. 8. Results: On May 10, 1996, the SecuritiesCommissioner for the State of Delaware, issued a consent order requiring that StrattonOakmont (a) withdraw its broker-dealer resistration in Delaware for a period of threeyears and not re-apply during that period of time; (b) pay restitution to the Delawareinvestor in the amount of $13,052.55.

Initiated By: DELAWARE SECURITIES DIVISION

Date Initiated:

Docket/Case Number: L-95-03-02





Resolution: ORDER


Sanctions Ordered:


Sanction Details:



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Disclosure



Allegations: RESPONDENT HAS A STATUTORY DISQUALIFIER BECAUSE OF A PERMANENTINJUNCTION

RESPONDENT HAS A STATUTORY DISQUALIFIER BECAUSE OF A PERMANENTINJUNCTION

Initiated By: MISSISSIPPI SECURITIES DIVISION

Date Initiated:








Sanctions Ordered:




Sanction Details: RESPONDENT'S LICENSE TO SELL SECURITIES IN THIS STATE HAS BEENSUSPENDED



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:





Resolution: ORDER


Sanctions Ordered:


Sanction Details: 12/21/94 SEC NEWS DIGEST, ISSUE 94-238, OAKMONT" THE SEC ANNOUNCEDTHE FILING OF A COMPLAINT IN THE U.S. DISTRICT COURT FOR THE DISTRICTOF COLUMBIA AGAINST STRATTON OAKMONT, INC. (STRATTON), AREGISTERED BROKER-DEALER, SEEKING A TEMPORARY RESTRAININGORDER, PRELIMINARY AND PERMANENT INJUNCTIONS RESTRAINING AND



ENJOINING STRATTON FROM VIOLATING AN ORDER ISSUED BY THE SEC ON3/17/94, AS WELL AS THE APPOINTMENT OF A SPECIAL COMPLIANCE MONITORTO ENSURE STRATTON'S COMPLIANCE WITH THE SEC'S ORDER. ACCORDINGTO THE COMPLAINT, STRATTON HAS DELIBERATELY REFUSED TO ABIDE BYTHE TERMS OF THE SEC ORDER TO WHICH IT CONSENTED AS PART OF ITSSETTLEMENT OF FRAUD CHARGES WITH THE SEC EARLIER THIS YEAR. (REL.14355) 12/27/94 SEC NEWS DIGEST ISSUE 94-241 THE U.S. DISTRICT COURTISSUED A TEMPORARY RESTRAINING ORDER ENJOINING STRATTON FROMVIOLATING THE SEC'S ORDER OF 3/17. THE COURT DIRECTED STRATTON TOIMPLEMENT THE CONSULTANT'S RECOMMENDATIONS BEFORE THEEXPIRATION OF THE TEMPORARY RESTRAINING ORDER ON 12/29/94. (LR-14360) 3/23/95 SEC NEWS DIGEST, ISSUE 95-40, THE SEC ANNOUNCED THAT ON2/28 THE U.S. DISTRICT COURT ISSUED A PERMANENT INJUNCTION ENJOININGSTRATTON FROM VIOLATING AN ORDER OF THE SEC ISSUED ON 3/17/94. INGRANTING THE PERMANENT INJUNCTION, THE COURT FOUND THATSTRATTON ADMITTED IT HAD NOT COMPLIED WITH THE PRELIMINARYINJUNCTION AND REJECTED STRATTON'S ARGUMENTS THAT THE INCLUSIONOF FINDINGS IN THE REPORT NULLIFIED STRATTON'S OBLIGATIONS TOCOMPLY WITH THE RECOMMENDATIONS AND THAT A PERMANENT INJUNCTIONWOULD CAUSE HARM TO STRATTON. [SEC V. STRATTON OAKMONT, INC., CIVILACTION NO. 94-2681, JHG, D.D.C.] (LR-14426) 5/31/95 SEC NEWS DIGEST, ISSUE95-102, THE U.S. DISTRICT COURT DENIED THE MOTION OF STRATTON TOVACATE OR MODIFY THE PERMANENT INJUNCTION ENTERED AGAINST IT ON2/28/95. [SEC V. STRATTON OAKMONT - 94 CIV. 2681, JHG] (LR-14506)



Regulatory - Final


Disclosure



Allegations: FAILED TO REASONABLY SUPERVISE ITS AGENT, STEVEN A. ANELLO.


Date Initiated:






Resolution: ORDER


Sanctions Ordered:


Sanction Details: STRATTON OAKMONT, INC. ENTERED INTO A CONSENT ORDER WHEREBY ITWILL CEASE VIOLATING THE KANSAS SECURITIES ACT AND WAS FINED $1,000.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: COMPLAINT NO. C10940044 FILED JULY 13, 1994 BY DISTRICT NO. 10 AGAINSTSTRATTON OAKMONT INC. ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT MEMBER PREPARED,UTILIZED AND EXECUTED AGREEMENTS WHEN SETTLING CUSTOMERCOMPLAINTS WHICH PRECLUDE, RESTRICT OR CONDITION A CUSTOMER'S



ABILITY TO COOPERATE WITH THE NASD IN CONNECTION WITH ANINVESTIGATION BY THE NASD OF THE CUSTOMER'S COMPLAINT; AND, FAILEDTO RELEASE A PUBLIC CUSTOMER FROM THE RESTRICTIVE PROVISIONS OF ASETTLEMENT AGREEMENT WHICH PRECLUDED, RESTRICTED AND/ORCONDITIONED THE CUSTOMER FROM COOPERATING WITH THE NASD'SINVESTIGATION OF THE CUSTOMER COMPLAINT MADE PURSUANT TO ARTICLEIV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISION RENDEREDAUGUST 7, 1995, WHEREIN RESPONDENT MEMBER IS CENSURED, FINED$20,000 AND ASSESSED COSTS OF $2,235. IN ADDITION, RESPONDENTMEMBER IS REQUIRED WITHIN 30 DAYS FROM THE DATE UPON WHICH THISDECISION BECOMES FINAL TO PROVIDE TO THE DISTRICT STAFF A LIST OF ALLCUSTOMERS WHO ARE CURRENTLY THE SUBJECT OF A SETTLEMENTAGREEMENT WHICH IMPOSED ANY FORM OF CONDITION ON THE CUSTOMER'SABILITY TO COOPERATE, ASSIST, OR PROVIDE INFORMATION TO THEASSOCIATION; NOTIFY AND RELEASE ALL CUSTOMERS WITH WHOM IT HASENTERED INTO ANY SETTLEMENT AGREEMENT WHICH IMPOSES ANY FORM OFCONDITION ON THE CUSTOMER'S ABILITY TO PROVIDE INFORMATION TO THEASSOCIATION FROM SUCH CONDITION AND TO SUBMIT PROOF THEREOF TOTHE DISTRICT STAFF, AND TO SUBMIT TO THE DISTRICT STAFF, ANDTHEREAFTER, UTILIZE IN ITS SETTLEMENT AGREEMENTS, A FORM OF OFFEROF SETTLEMENT CONTAINING NON-DISCLOSURE AND CONFIDENTIALITYCLAUSES, IF ANY, NOT UNACCEPTABLE IN FORM TO THE DISTRICT STAFF.(SHOULD RESPONDENT MEMBER SEEK, FROM TIME TO TIME, TO MODIFY ANYSUCH CLAUSE SUCH MODIFICATION MUST BE SUBMITTED TO, AND NOT BEUNACCEPTABLE TO, THE DISTRICT'S STAFF.) FAILURE TO COMPLY WITHTHESE REQUIREMENTS SHALL RESULT IN THE SUSPENSION OFRESPONDENT'S MEMBERSHIP UNTIL SUCH TIME AS THE NASD SHALLDETERMINE THAT IT IS IN COMPLIANCE WITH THESE REQUIREMENTS AND SONOTIFIES THE RESPONDENT. IF NO FURTHER ACTION, DECISION IS FINALSEPTEMBER 21, 1995. AUGUST 22, 1995 -- APPEALED TO BOARD. NBCCDECISION RENDERED APRIL 16, 1996 WHEREIN THE FINDINGS MADE AREAFFIRMED AND THE SANCTIONS IMPOSED ARE MODIFIED; THEREFORE,RESPONDENT MEMBER IS CENSURED, FINED $20,000, ASSESSED DBCC COSTSOF $2,235, REQUIRED WITHIN 30 DAYS TO SUBMIT TO THE DISTRICT STAFF,AND THEREAFTER UTILIZE IN ITS SETTLEMENT AGREEMENTS, A FORM OFOFFER OF SETTLEMENT CONTAINING NON-DISCLOSURE ANDCONFIDENTIALITY CLAUSES, IF ANY, ACCEPTABLE IN FORM TO THE DISTRICTSTAFF (SHOULD STRATTON SEEK, FROM TIME TO TIME, TO MODIFY SUCHCLAUSE, THE PROPOSED MODIFICATION MUST ALSO BE SUBMITTED ANDACCEPTABLE TO THE DISTRICT STAFF); AND, WITHIN 30 DAYS OF ANYREQUEST BY THE NASD ISSUED IN CONNECTION WITH ITS INVESTIGATIVE



DUTIES, ANY IDENTIFIED CUSTOMER SHOULD BE RELEASED FROM ASETTLEMENT AGREEMENT WHICH IMPOSES ANY FORM OF CONDITION ON ACUSTOMER'S ABILITY TO PROVIDE INFORMATION TO THE NASD. PROOF OFCOMPLIANCE SHOULD BE SUBMITTED TO THE DISTRICT STAFF AND FAILURETO COMPLY WITH THESE REQUIREMENTS SHALL RESULT IN THE SUSPENSIONOF THE FIRM'S MEMBERSHIP UNTIL THE NASD DETERMINES THAT THE FIRM ISIN COMPLIANCE. IF NO FURTHER ACTION, DECISION IS FINAL MAY 16, 1996.MAY 22, 1996 - APPEALED TO THE SEC.********************************************************* 03-14-97, SEC NEWS DIGESTISSUE NO. 97-49, DATED MARCH 13, 1997, ENFORCEMENT PROCEEDINGSDISCLOSE: "NASD FINDINGS OF VIOLATIONS AGAINST STRATTON OAKMONT,INC SUSTAINED: SANCTIONS MODIFIED IN LIGHT OF LIQUIDATIONPROCEEDING"; THE COMMISSION HAS SUSTAINED THE NASD'S FINDINGS THATSTRATTON OAKMONT, INC. (STRATTON), A FORMER NASD MEMBER FIRM,UTILIZED CUSTOMER SETTLEMENT AGREEMENTS WITH CONFIDENTIALITYPROVISIONS THAT IMPERMISSIBLY RESTRICTED THE CUSTOMERS' ABILITY TODISCUSS THE SUBSTANCE OF THEIR COMPLAINTS WITH THE NASD. THECOMMISSION ALSO HAS SUSTAINED THE NASD'S FINDINGS THAT STRATTONACTED WRONGLY WHEN, DESPITE REPEATED REQUESTS BY THE NASD TO DOSO, STRATTON FAILED TO RELEASE ONE CUSTOMER FROM THECONFIDENTIALITY PROVISION IN HIS SETTLEMENT AGREEMENT SO THAT THENASD COULD INVESTIGATE THE CUSTOMER'S COMPLAINT. THE NASDCENSURED STRATTON, FINED THE FIRM $20,000 AND ASSESSED COSTS. THISCASE FOCUSED ON WHETHER IT WAS PROPER FOR A FIRM TO HAVE ITSCUSTOMERS EXECUTE SETTLEMENT AGREEMENTS CONTAINING PROVISIONSTHAT OBSTRUCT THE NASD'S INVESTIGATIONS OF THE CUSTOMERS'COMPLAINTS. THE COMMISSION DETERMINED THAT SEVERAL OF STRATTON'SCUSTOMER SETTLEMENT AGREEMENTS VIOLATED JUST AND EQUITABLEPRINCIPLES OF TRADE BY IMPEDING NASD INVESTIGATIONS ANDINTERFERING WITH THE NASD'S REGULATORY FUNCTIONS. THE COMMISSIONALSO CONCLUDED THAT STRATTON'S FAILURE TO RELEASE A CUSTOMERFROM THE CONFIDENTIALITY PROVISION OF HIS SETTLEMENT AGREEMENTWHEN DIRECTED TO DO SO BY THE NASD WAS AN ADDITIONAL VIOLATION OFJUST AND EQUITABLE PRINCIPLES OF TRADE. BECASUE OF STRATTON'SPENDING LIQUIDATION, THE COMMISSION MODIFIED THE NASD'S SANCTIONSTO PROVIDE THAT ANY EFFORTS TO COLLECT THE FINE AND COSTS BEPURSUED IN STRATTON'S LIQUIDATION PROCEEDING UNDER THE SECURITIESINVESTOR PROTECTION ACT. A SEPARATE, UNRELATED DISCIPLINARYMATTER IN WHICH THE NASD EXPELLED STRATTON FROM MEMBERSHIP ISPENDING BEFORE THE COMMISSION. (REL. 34-38390) **OCTOBER 12, 1996 - THESEC ORDERED THAT THE FINDINGS MADE BY THE NASD HEREBY ARE



SUSTAINED, AND THE SANCTIONS IMPOSED ARE MODIFIED TO PROVIDE THATANY EFFORTS TO COLLECT THE FINE IMPOSED AND THE COSTS ASSESSEDSHALL BE PURSUED AS A CLAIM IN STRATTON OAKMONT'S LIQUIDATIONPROCEEDING UNDER THE SECURITIES INVESTOR PROTECTION ACT OF 1970.**$22,235.00 PAID ON 5/17/96, INVOICE #98-10-250**



Regulatory - Final


Disclosure



Allegations: ON 4/12/94, THE COMMISSIONER ISSUED AN ORDER TO SHOW CAUSE ANDSUMMARY SUSPENSION BASED ON A BAR AND SUSPENSION ISSUED BY THESEC ON PRINCIPALS BELFORT AND GREENE, PURSUANT TO SEC. 11-412(a)(4)OF THE ACT.

Initiated By: MARYLAND DIVISION OF SECURITIES

Date Initiated:

Docket/Case Number: BD-94-0132





Resolution: ORDER


Sanctions Ordered:


Sanction Details: SUBSEQUENT TO THE ISSUANCE OF THE ORDERS, STRATTON SUBMITTED TOTHE DIVISION, REPRESENTATIONS THAT BELFORT AND GREENE ARE NO



LONGER ASSOCIATED WITH OR EMPLOYED BY STRATTON OAKMONT.

THE COMMISSIONER ACCEPTED A CONSENT ORDER WHEREBY STRATTONOAKMONT AGREES TO: (1) ANY SANCTION IMPOSED BY ANOTHERJURISDICTION, SRO, EXCHANGE, SEC, OR THE COMMODITY FUTURES TRADINGCOMMISSIONER, WILL RESULT IN THIS ENTIRE MATTER BEING REVIEWED BYTHE DIVISON; (2) WITHIN 30 DAYS OF RECEIPT, STRATTON AGREES TOFORWARD TO THE DIVISION A COPY, IF WRITTEN, OR A SYNOPSIS, IF VERBAL,OF EACH CUSTOMER COMPLAINT THAT IS RECEIVED FROM A MARYLANDRESIDENT OR FROM A CUSTOMER DOING BUSINESS WITH ANY OFSTRATTON'S MARYLAND OFFICES, AGENTS, OR EMPLOYEES, AND A COPY OFSTRATTON'S RESPONSE TO THAT COMPLAINT; (3) ANY CUSTOMER COMPLAINTINVOLVING STRATTON WILL RESULT IN THIS ENTIRE MATTER BEING REVIEWEDBY THE DIVISION, INCLUDING, BUT NOT LIMITED TO, THOSE MATTERS THATFORM THE BASIS OF THIS ACTION. CONTACT: ELLEN E. CHERRY, (410) 576-6494. B/D REGISTRATION REINSTATED 4/20/94.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: 6/10/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920048-AWC:A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED APRIL 2, 1992AGAINST RESPONDENT MEMBER STRATTON OAKMONT, INC. ALLEGINGVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT THEFOLLOWING RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:



THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THEMARKET SURVEILLANCE COMMITTEE ON MAY 8, 1992 AND BY THE NATIONALBUSINESS CONDUCT COMMITTEE ON JUNE 3, 1992. $1,500.00 FINE. **$1,500.00PAID ON 6/22/92 INVOICE #92-MS-573**



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920027 AWC (A) LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 11, 1992 AGAINSTRESPONDENT MEMBER STRATTON OAKMONT, INC. ALLEGING VIOLATIONS OFPART VI, SECTION 5(a) OF SCHEDULE D IN THAT THE FOLLOWINGRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME: THE LETTER OF



ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKETSURVEILLANCE COMMITTEE ON MARCH 18, 1992 AND BY THE NATIONALBUSINESS CONDUCT COMMITTEE ON APRIL 7, 1992. ***$250.00 FINE*****$250.00 PAID ON 5/13/92 INVOICE #92-MS-403**



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:





Resolution: ORDER


Sanctions Ordered:


Sanction Details: 4/7/92 SEC NEWS DIGEST, ISSUE 92-55, DATED 3/20/92 CIVIL PROCEEDINGSDISCLOSES; ON MARCH 20, THE COMMISSION FILED A COMPLAINT IN THE U.S.DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK SEEKINGPRELIMINARY AND PERMANENT INJUNCTIVE RELIEF AGAINST STRATTONOAKMONT, INC. (STRATTON), BASED UPON ALLEGED VIOLATIONS OF THE



ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. THE COMPLAINTALLEGES THAT SINCE MARCH 1989, STRATTON, HAS OPERATED A BOILERROOM, USING HIGH PRESSURE AND FRAUDULENT SALES PRACTICES TO SELLSPECULATIVE OVER-THE-COUNTER SECURITIES OF UNSEASONED COMPANIESTO THE INVESTING PUBLIC. THE COMPLAINT ALSO ALLEGES THAT STRATTONEARNED APPROXIMATELY $11 MILLION IN CONNECTION WITH ITSMANIPULATION OF THE MARKET FOR NOVA CAPITAL, INC. COMMON STOCK.[SEC V. STRATTON OAKMONT, INC., et al., CIVIL ACTION NO. 92 CIV. 1993, JFS](LR-13195)*** 2/8/94: SEC NEW DIGEST, ISSUE 94-22, DATE 2/3/94 CIVIL ACTIONDISCLOSES; "THE COMMISSION ACCEPTED THE OFFERS OF SETTLEMENT OFSTRATTON TO PAY DISGORGEMENT OF $1,537,146 PLUS PREJUDGMENTINTEREST OF $518,622, TO BE USED TO COMPENSATE STRATTONCUSTOMERS, AND CIVIL PENALTIES OF $500,000. FURTHER, STRATTONCONSENTED TO AN ORDER THAT CENSURES STRATTON AND ORDERS IT TOCOMPLY WITH CERTAIN REMEDIAL UNDERTAKINGS. 4/4/95 SEC NEWS DIGEST,ISSUE 94-56 DATED 3/25/94 ENFORCEMENT PROCEEDINGS DISCLOSES; THESAME INFORMATION AS SEC NEWS DIGEST, ISSUE 94-22 WITH THE LITIGATIONRELEASE NUMBER BEING (REL. 34-33778). 11/16/94 SEC DOCKET, VOLUME 56,NO. 6, DATED 4/5/94 5, 1994, PAGE 822, DISCLOSES; ORDER OF DISGORGEMENTAGAINST ESPONDENT STRATTON IS DATED 3/17/94. THIS ORDER ALSOREQUIRES THAT STRATTON RETAIN AN INDEPENDENT CONSULTANT TOUNDERTAKE A REVIEW OF ALL OF STRATTON'S POLICIES, PRACTICES ANDPROCEDURES, WHICH AFORESAID POLICIES SHALL BE ADOPTED,IMPLEMENTED AND MAINTAINED BY STRATTON. AN INDEPENDENT AUDITORSHALL ALSO BE RETAINED TO CONDUCT 4 SPECIAL REVIEWS OF SAIDPOLICIES.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1089-AWC: (A) LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 11, 1991 AGAINSTRESPONDENT MEMBER STRATTON OAKMONT, INC. ALLEGING VIOLATIONS OFSECTION c).3(C) OF THE ASSOCIATION'S SEOS RULES AND THE MAXIMUMORDER SIZE IMTERPRETATION BY RESPONDENTS: THE LETTER OF



ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKETSURVEILLANCE COMMITTEE ON SEPTEMBER 6, 1991 AND BY THE NATIONALBUSINESS CONDUCT COMMITTEE ON DECEMBER 27, 1991. ***$5,000 JOINT ANDSEVERAL; AND AN UNDERTAKING BY STARATTON TO IMPLEMENT WRITTENSUPERVISORY PROCEDURES DESIGNED TO ACHIEVE COMPLAINCE WITH THESOES RULES AND ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OFFAIR PRACTICE AND THE BOARD OF GOVERNOR'S INTERPRETATIONREGARDING "PROMPT RECEIPT AND DELIVERY OF SECURITIES." ***$5,000.00J&S PAID ON 1/22/92 INVOICE #92-MS-59***



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: ON JULY 30, 1990, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO.NY-9018-AWC (DISTRICT NO. 12) SUBMITTED BY RESPONDENTS STRATTONOAKMONT INC. AND STEVEN SANDERS WAS ACCEPTED; THEREFORERESPONDENT MEMBER IS CENSURED AND RESPONDENT SANDERS ISCENSURED AND FINED $2,500 (ARTICLE III, SECTION 1 OF THE RULES OF FAIR



PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENTSANDERS, FAILED TO ABIDE BY THE LIMITATIONS SET FORTH IN ITSRESTRICTION AGREEMENT BY INCREASING ITS MARKET MAKING ACTIVITY TOOVER 30 SECURITIES).



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-842-AWC: LETTER OFACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 18, 1989 AGAINSTRESPONDET STRATTON OAKMONT INC. ALLEGING VIOLATIONS OF PART VI,SECTION 5(a) OF SCHEDULE D IN THAT RESPONDENTS FAILED TO REPORTTHEIR NASDAQ VOLUME. THE LETTER OF ACCEPTANCE, WAIVER AND



CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ONNOVEMBER 10, 1989 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEEDECEMBER 12, 1989. $500 FINE. ***$500.00 PAID ON 3/5/90 INVOICE #90-MS-94***



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: 11/4/89< MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-826-AWC:LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON JULY18, 1989, ALLEGING VIOLATIONS OF PART VI, SECTION 4(a) OF SCHEDULE D INTHAT RESPONDENT FAILED TO REPORT NASDAQ VOLUME. THE AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON AUGUST 30, 1989



AND BY THE NBCC ON SEPTEMBER 25, 1989. THE RESPONDENT WAS FINED INTHE AMOUNT OF $250. *** $250 PAID ON 10/30/89 - INVOICE NO. 89-MS-748.



Regulatory - Final


Disclosure



Allegations:


Date Initiated:

Docket/Case Number:







Sanctions Ordered:


Sanction Details: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-800-AWC: LETTER OFACCEPTANCE, WAIVER AND CONSENT FILED APRIL 13, 1989 AGAINSTRESPONDENT OAKMONT SECURITIES INC. ALLEGING VIOLATIONS OF PART VI,SECTION 4(a) OF SCHEDULE D IN THAT RESPONDENT FAILED TO REPORT ITSNASDAQ VOLUME. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS



ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON JUNE 6, 1989 ANDBY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON JULY 13, 1989. $750FINE *****$750.00 PAID 8/18/89.



Regulatory - Final


Disclosure

Reporting Source:

Current Status:

Allegations:

Initiated By:

Date Initiated:

Docket/Case Number:





Resolution:

Resolution Date:

Sanctions Ordered:


Sanction Details:



Regulatory - Pending

This section provides information regarding a pending regulatory action as reported by the firm and/or a securitiesregulator to CRD. The event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, a self-regulatory organization, a federal regulator such as the U.S. Securities and ExchangeCommission (SEC) or the Commodity Futures Trading Commission (CFTC), or a foreign financial regulatory body) foralleged violations of investment-related rules or regulations.

Disclosure


Current Status:

Allegations: THE ADMINISTRATOR HAS SUFFICIENT GROUNDS TO REVOKE THE BROKER-DEALER LICENSE OF RESPONDENT, STRATTON OAKMONT, INC. PURSUANT TOTHE PROVISIONS OF NRS 90.420.1(b), NRS 90.420.1(e), NRS 90.420.1(g)(1) AND(2), NRS 90.420.1(h), NRS 90.420.1(i), AND NRS 90.420.1(k) FOR THE FOLLOWINGREASONS: A. THE DIVISION REQUESTED COPIES OF TELEPHONECONVERSATIONS BETWEEN ROB KOCH, A SALES REPRESENTATIVE FORSTRATTON OAKMONT, INC. AND A NEVADA CUSTOMER PURSUANT TO AFORMAL WRITTEN REQUEST BY THE DIVISION. THE TAPES SHOULD HAVECOVERED THE CONVERSATIONS RELATING TO THE SALE OF 75,000 SHARESOF DOLLAR TIME GROUP INC. AND 38,000 UNITED LEISURE CORP. WARRANTSWHICH SETTLED ON FEBRUARY 3, 1995 WERE NEVER RECEIVED BY THEDIVISION; B. THE PERMANENT INJUNCTION AGAINST STRATTON OAKMONT ONFEBRUARY 28, 1995 BY JUDGE JOYCE HENS GREEN IN AN ACTION BROUGHT BYTHE SEC; C. ACTIONS TAKEN BY FIVE OTHER STATES; D. THE EXPULSION OFSTRATTON OAKMONT, INC. BY THE NASD AND THE SEC ORDER ON DECEMBER6, 1996 DENYING A STAY OF THE NASD SANCTIONS EXCEPT THE "EXPULSIONOF STRATTON OAKMONT, INC. SHALL NOT BE EFFECTIVE FOR FIVE BUSINESSDAYS AFTER THE DATE OF THIS ORDER, SOLELY TO THE EXTENT THAT,DURING THIS PERIOD STRATTON OAKMONT, INC. MAY EFFECT ON BEHALF OFITS EXISTING CUSTOMERS UNSOLICITED LIQUIDATING TRANSACTIONS, ON ANAGENCY BASIS." D. RESPONDENT, STRATTON OAKMONT, INC., DID, THROUGHITS AGENTS AND LICENSED SALES REPRESENTATIVES, JORDAN I SHAMAHAND IRVING STITSKY ENGAGE IN UNETHICAL AND DISHONEST PRACTICES INTHE SECURITIES BUSINESS BY PERFORMING UNAUTHORIZED TRADES IN ANDEXCESSIVE TRADING OF THE INCOME TRUST ACCOUNT OF TWO NEVADARESIDENTS, AND FOR WHICH ONE OF THE NEVADA RESIDENTS WAS THETRUSTEE; E. RESPONDENT, STRATTON OAKMONT, INC., HAS ENGAGED INUNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS BY



FAILING TO ABIDE BY THE TERMS AND CONDITIONS OF A SETTLEMENTAGREEMENT WITH A NEVADA RESIDENT; F. RESPONDENT, STRATTONOAKMONT, INC., HAS EXHIBITED INSOLVENCY BY ITS FAILURE TO HONOR ITSCURRENT LEGAL OBLIGATIONS TO A NEVADA RESIDENT; G. RESPONDENT,STRATTON OAKMONT, INC., FAILED REASONABLY TO SUPERVISE ITS SALESREPRESENTATIVES, IRVING STITSKY AND JORDAN I SHAMAH; AND H. THEORDER IS ISSUED PURSUANT TO A FINDING BY THE ADMINISTRATOR THATTHE ORDER IS IN TH PUBLIC INTEREST AND THE ACTION TAKEN IS NECESSARYFOR THE PROTECTION OF THE PUBLIC.

Initiated By: NEVADA SECRETARY OF STATE, SECURITIES DIVISION

Date Initiated: 01/09/1997

Docket/Case Number: I95-35







Customer Dispute – Award/Judgment

Firms are not required to report arbitration claims filed against them by customers on Form BD; however, FINRA providessummary information regarding FINRA arbitration awards involving securities and commodities disputes between publiccustomers and FINRA-registered firms in this section of the report. Note: an arbitration may contain multiple instances of acertain Relief Type (e.g., Actual/Compensatory Damages) requested by or awarded to one or more Claimants.

The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure

Reporting Source: NASD

Type of Event: ARBITRATION

Allegations: MISREPRESENTATION; ACCOUNT RELATED-OTHER

Arbitration Forum: NASD

Case Initiated: 10/24/1995

Case Number: 95-04040

Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $7,010.00; INTEREST, ASKEDAMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $150.00; ACTUAL/COMPENSATORYDAMAGES, ASKED AMOUNT $234.50

Disposition: AWARD AGAINST PARTY

Disposition Date: NOT PROVIDED

Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEFREQUEST HAS BEEN DENIED IN FULL; ACTUAL/COMPENSATORY DAMAGES, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $234.50






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; BRCH OF FIDUCIARY DT; ACCOUNTRELATED - FAILURE TO SUPERVISE




Disputed Product Type: COMMON STOCK

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $22,779.00; INTEREST,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00; ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT$23,161.00


Disposition Date: 06/04/1996

Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $21,227.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEENDENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: MISREPRESENTATION; ACCOUNT RELATED - FAILURE TO SUPERVISE;UNAUTHORIZED TRADING; CHURNING




Disputed Product Type: UNKNOWN TYPE OF SECURITIES

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $602,500.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; TREBLE DAMAGES,ASKED AMOUNT $1,205,000.00; INTEREST, ASKED AMOUNT $0.00; ATTORNEY'SFEES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $496,826.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $837,490.00 JOINTLY AND SEVERALLY; TREBLE DAMAGES,RELIEF REQUEST HAS BEEN DENIED IN FULL; INTEREST, RELIEF REQUEST HASBEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIALOR FULL), AWARD AMOUNT $65,000.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $7,635.00; OTHER COSTS,ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER COSTS, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$150.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: SUITABILITY; OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00; OTHER COSTS, ASKEDAMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $28,487.50; PUNITIVE/EXEMPLARY DAMAGES, RELIEFREQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $18,270.00 JOINTLY ANDSEVERALLY; INTEREST, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL); OTHERCOSTS, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$2,561.00 JOINTLY AND SEVERALLY; OTHER MONETARY RELIEF, RELIEF REQUESTHAS BEEN DENIED IN FULL






Disclosure








Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $7,000.00; INTEREST, ASKEDAMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $7,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL); OTHER COSTS, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $75.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: ACCOUNT RELATED-OTHER




Disputed Product Type: COMMON STOCK; WARRANTS/RIGHTS

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $8,975.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $3,193.75 JOINTLY AND SEVERALLY






Disclosure







Disputed Product Type: WARRANTS/RIGHTS




Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $10,000.00






Disclosure








Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $5,500.00; OTHERMONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $1,750.00; OTHER MONETARY RELIEF, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $150.00






Disclosure



Allegations: EXECUTIONS-FAILURE TO EXECUTE; SUITABILITY














Disclosure



Allegations: SUITABILITY; BRCH OF FIDUCIARY DT; OMISSION OF FACTS














Disclosure



Allegations: SUITABILITY; MISREPRESENTATION; OMISSION OF FACTS; ACCOUNT RELATED -FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $81,312.00; INTEREST,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $40,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: UNAUTHORIZED TRADING; MISREPRESENTATION; CHURNING; ACCOUNTRELATED-OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $1,152,504.00; ATTORNEY'SFEES, ASKED AMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00; OTHER COSTS,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $712,000.00 JOINTLY AND SEVERALLY; ATTORNEY'S FEES,RELIEF REQUEST HAS BEEN DENIED IN FULL; INTEREST, RELIEF REQUEST HASBEEN DENIED IN FULL; OTHER COSTS, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $1,250.00 JOINTLY AND SEVERALLY; PUNITIVE/EXEMPLARYDAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$15,000.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: UNAUTHORIZED TRADING; ACCOUNT RELATED - FAILURE TO SUPERVISE;MISREPRESENTATION; OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $72,019.35;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $4,700,000.00; TREBLEDAMAGES, ASKED AMOUNT $144,038.70; INTEREST, ASKED AMOUNT $0.00;ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00;OTHER MONETARY RELIEF, ASKED AMOUNT $20,000.00; ACTUAL/COMPENSATORYDAMAGES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $59,978.10 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;TREBLE DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL; INTEREST,RELIEF REQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIEDIN FULL; ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED



(PARTIAL OR FULL), AWARD AMOUNT $12,041.25 JOINTLY AND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; SUITABILITY; ACCOUNT RELATED-NEGLIGENCE




Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES; WARRANTS/RIGHTS

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $70,000.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00; OTHER COSTS,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; OTHER MONETARYRELIEF, ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00;ATTORNEY'S FEES, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT$0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $20,000.00 JOINTLY AND SEVERALLY;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS,RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER MONETARY RELIEF, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER MONETARY RELIEF, RELIEF



REQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED INFULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED INFULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED INFULL; INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL; INTEREST, RELIEFREQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; BRCH OF FIDUCIARY DT; ACCOUNTRELATED - FAILURE TO SUPERVISE














Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; SUITABILITY





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $6,167.00; INTEREST, ASKEDAMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $6,167.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL)






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; SUITABILITY; BRCH OF FIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $122,000.00 JOINTLY AND SEVERALLY;ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL); ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL),AWARD AMOUNT $25,000.00 JOINTLY AND SEVERALLY; OTHER COSTS, RELIEF HASBEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $600.00 JOINTLY ANDSEVERALLY; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEENDENIED IN FULL; INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: UNAUTHORIZED TRADING; EXECUTIONS-FAILURE TO EXECUTE;MISREPRESENTATION














Disclosure



Allegations: MISREPRESENTATION; CHURNING; BRCH OF FIDUCIARY DT; ACCOUNT RELATED -FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $48,274.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $2,293.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARYDAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00;OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $32,000.00 JOINTLY AND SEVERALLY;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEFREQUEST HAS BEEN DENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEFREQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL; OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN



DENIED IN FULL






Disclosure



Allegations: MANIPULATION; OTHER














Disclosure



Allegations: UNAUTHORIZED TRADING; EXECUTIONS-FAILURE TO EXECUTE; MANIPULATION;ACCOUNT RELATED - FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $61,200.00; INTEREST,ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;SPECIFIC PERFORMANCE, ASKED AMOUNT



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $16,593.75 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL); ATTORNEY'S FEES, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $5,531.25 JOINTLY ANDSEVERALLY; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;SPECIFIC PERFORMANCE, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: MISREPRESENTATION; EXECUTIONS-OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $10,000.00; INTEREST,ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $7,385.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL); OTHER MONETARY RELIEF, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL)






Disclosure



Allegations: ACCOUNT RELATED - FAILURE TO SUPERVISE; MISREPRESENTATION; BRCH OFFIDUCIARY DT; OMISSION OF FACTS





Relief Sought: ATTORNEY'S FEES, ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES,ASKED AMOUNT $0.00



Relief Awarded: ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $1,200,000.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: SUITABILITY; MISREPRESENTATION; OMISSION OF FACTS; ACCOUNT RELATED -FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $9,812.61; INTEREST, ASKEDAMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKEDAMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $9,812.61; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL); ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $1,000.00; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER MONETARY RELIEF, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT $150.00






Disclosure



Allegations: BRCH OF FIDUCIARY DT; OMISSION OF FACTS; MISREPRESENTATION; SUITABILITY





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $100,000.00; OTHERMONETARY RELIEF, ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKEDAMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;ATTORNEY'S FEES, ASKED AMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00;OTHER COSTS, ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKEDAMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $100,000.00 JOINTLY AND SEVERALLY; OTHER MONETARYRELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER MONETARY RELIEF,RELIEF REQUEST HAS BEEN DENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES,RELIEF REQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEFREQUEST HAS BEEN DENIED IN FULL; INTEREST, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER COSTS, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL),AWARD AMOUNT $287.75 JOINTLY AND SEVERALLY; OTHER MONETARY RELIEF,RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: EXECUTIONS-EXECUTION PRICE; EXECUTIONS-FAILURE TO EXECUTE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $142,000.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $42,000.00; INTEREST,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $70,000.00 JOINTLY AND SEVERALLY;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEFREQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; UNAUTHORIZED TRADING;CHURNING





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $4,400,000.00; INTEREST,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $2,995,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $50,000.00 JOINTLYAND SEVERALLY; PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT $22,000.00 JOINTLY AND SEVERALLY; OTHERMONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: SUITABILITY; CHURNING; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED -FAILURE TO SUPERVISE




Disputed Product Type: COMMON STOCK; OTHER TYPES OF SECURITIES

Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $158,666.61; INTEREST,ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $157,681.61; INTEREST, RELIEF REQUEST HAS BEENDENIED IN FULL; ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $12,000.00; PUNITIVE/EXEMPLARY DAMAGES, RELIEF HASBEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $75,000.00






Disclosure



Allegations: MISREPRESENTATION; SUITABILITY; BRCH OF FIDUCIARY DT














Disclosure



Allegations: CHURNING; SUITABILITY; OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $906,492.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $1,000,000.00; ATTORNEY'SFEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; OTHERMONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $965,000.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS,RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER MONETARY RELIEF, RELIEFREQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; BRCH OF FIDUCIARY DT;ACCOUNT RELATED - FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $279,000.00; OTHER COSTS,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00;TREBLE DAMAGES, ASKED AMOUNT $0.00; ACTUAL/COMPENSATORY DAMAGES,ASKED AMOUNT $279,000.00; OTHER COSTS, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; TREBLE DAMAGES,ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $144,552.51 JOINTLY AND SEVERALLY; OTHER COSTS,RELIEF REQUEST HAS BEEN DENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES,RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $140,635.00JOINTLY AND SEVERALLY; TREBLE DAMAGES, RELIEF REQUEST HAS BEENDENIED IN FULL; ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $140,635.00 JOINTLY ANDSEVERALLY; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL;



PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $119,552.50 JOINTLY AND SEVERALLY; TREBLE DAMAGES,RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: UNAUTHORIZED TRADING; MANIPULATION; OMISSION OF FACTS; BRCH OFFIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $20,758.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $1,530.00;ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $87,200.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKEDAMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $91,839.40 JOINTLY AND SEVERALLY;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES,RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUESTHAS BEEN DENIED IN FULL






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; BRCH OF FIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $50,000.00; INTEREST,ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $50,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $17,198.63 JOINTLYAND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION; ACCOUNT RELATED - FAILURE TO SUPERVISE; BRCH OFFIDUCIARY DT; SUITABILITY




Disputed Product Type: COMMON STOCK; PREFERRED STOCK; WARRANTS/RIGHTS










Disclosure



Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; BRCH OF FIDUCIARY DT; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED - FAILURE TO SUPERVISE














Disclosure



Allegations: UNAUTHORIZED TRADING; MISREPRESENTATION; SUITABILITY; OMISSION OFFACTS





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $79,155.00; OTHERMONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $43,565.00 JOINTLY AND SEVERALLY; OTHER MONETARYRELIEF, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$5,000.00






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $67,518.00; INTEREST,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $39,803.96 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL); OTHER COSTS, RELIEF REQUEST HASBEEN DENIED IN FULL






Disclosure



Allegations: CHURNING; ACCOUNT RELATED - FAILURE TO SUPERVISE; SUITABILITY; OTHER














Disclosure



Allegations: MISREPRESENTATION; MANIPULATION; OMISSION OF FACTS; SUITABILITY





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $33,315.54; INTEREST,ASKED AMOUNT $0.00; TREBLE DAMAGES, ASKED AMOUNT $66,631.08;ATTORNEY'S FEES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $23,128.91 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $5,850.93 JOINTLY ANDSEVERALLY; TREBLE DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARDAMOUNT $43,750.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: BRCH OF FIDUCIARY DT; UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-ERRORS-CHARGES














Disclosure



Allegations: SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED - FAILURE TOSUPERVISE; OTHER





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $400,000.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; OTHER MONETARYRELIEF, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHERCOSTS, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $218,584.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER COSTS,RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: EXECUTIONS-FAILURE TO EXECUTE














Disclosure



Allegations: EXECUTIONS-FAILURE TO EXECUTE; EXECUTIONS-EXECUTION PRICE














Disclosure



Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE;SUITABILITY; UNAUTHORIZED TRADING





Relief Sought: ATTORNEY'S FEES, ASKED AMOUNT $0.00



Relief Awarded: ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARDAMOUNT $5,000.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; BRCH OF FIDUCIARY DT; ACCOUNTRELATED-BREACH OF CONTRACT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $95,500.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $75,000.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $66,000.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $50,000.00 JOINTLY AND SEVERALLY ***** =1/20/95=CORRES. REC'D (8000 01995) DISCLOSES A COPY OF MEMORANDUM AND ORDERISSUED BY THE U.S.D.C. EASTERN DISTRICT OF NEW YORK VACATING A PORTIONOF THE AWARD IN CASE NO. 92-01316: "... THE ARBITRATION WAS CONVENED ON2/2/94 BEFORE A PANEL OF 3 ARBITRATORS APPOINTED BY THE NASD. AT THECONCLUSION OF THE HEARING, THE ARBITRATORS RENDERED A UNANIMOUSDECISION IN FAVOR OF NICHOLSON (CLAIMANT) AND ISSUED THEIR AWARD ON3/15/94. THE ARBITRATION PANEL AWARDED $66,000 PLUS INTEREST INCOMPENSATORY DAMAGES TO NICHOLSON, TO BE PAID JOINTLY AND SEVERALLY



BY STRATTON OAKMONT AND HONIGMAN. THE PANEL ALSO AWARDED A TOTALOF $50,000 IN PUNITIVE DAMAGES TO NICHOLSON, HALF TO BE PAID BYSTRATTON AND HALF BY HONIGMAN. STRATTON AND HONIGMAN PRESENTLYMOVE TO VACATE THE ENTIRE AWARD ON THE GROUND THAT THE ARBITRATORSEXCEEDED THEIR POWERS BY AWARDING PUNITIVE DAMAGES.... FOR THEFOREGOIND REASONS, IT IS HEREBY ORDERED, THAT THE PLAINTIFF'S MOTIONPURSUANT TO 9 U.S.D.C. TO VACATE THE ARBITRATION AWARD # 92-01316, ISGRANTED TO THE EXTENT THAT THE PUNITIVE DAMAGES PORTION OF THATAWARD AGAINST THE PLAINTIFFS STRATTON AND HONIGMAN IS VACATED, AND ISDENIED IN ALL OTHER ASPECTS. THE REMAINING PORTION OF THE ARBITRATIONAWARD REGARDING COMPENSATORY DAMAGES AND THE PARTIES BEARINGTHEIR RESPECTIVE COSTS, INCLUDING ATTORNEY'S FEES, ARE AFFIRMED ANDREMAIN IN EFFECT." DATED 11/11/94 AND SIGNED BY ARTHUR D. SPATT, U.S.DISTRICT JUDGE.






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $150,000.00; ATTORNEY'SFEES, ASKED AMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $110,000.00 JOINTLY AND SEVERALLY; ATTORNEY'S FEES,RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $50,000.00JOINTLY AND SEVERALLY; INTEREST, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $46,000.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: SUITABILITY; UNAUTHORIZED TRADING; CHURNING; MISREPRESENTATION








Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $48,632.00 JOINTLY AND SEVERALLY; OTHER COSTS,RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $750.00JOINTLY AND SEVERALLY






Disclosure



Allegations: SUITABILITY; CHURNING; MISREPRESENTATION; OMISSION OF FACTS














Disclosure



Allegations: CHURNING; MISREPRESENTATION; OTHER








Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $2,610.00; OTHER COSTS, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT $125.00






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; SUITABILITY; ACCOUNT RELATED-NEGLIGENCE














Disclosure



Allegations: MISREPRESENTATION; SUITABILITY; BRCH OF FIDUCIARY DT




Disputed Product Type: CORPORATE BONDS; WARRANTS/RIGHTS










Disclosure



Allegations: EXECUTIONS-FAILURE TO EXECUTE; BRCH OF FIDUCIARY DT














Disclosure



Allegations: MISREPRESENTATION; SUITABILITY; UNAUTHORIZED TRADING; BRCH OFFIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $266,169.88; TREBLEDAMAGES, ASKED AMOUNT $750,000.00; OTHER MONETARY RELIEF, ASKEDAMOUNT $1,250,000.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $275,000.00 JOINTLY AND SEVERALLY; TREBLE DAMAGES,RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER MONETARY RELIEF, RELIEFREQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: SUITABILITY; MISREPRESENTATION; OMISSION OF FACTS





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $10,000.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; OTHER COSTS, ASKEDAMOUNT $0.00; OTHER NON-MONETARY RELIEF, ASKED AMOUNT



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $10,000.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER NON-MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: SUITABILITY; CHURNING; MISREPRESENTATION














Disclosure



Allegations: UNAUTHORIZED TRADING; MISREPRESENTATION














Disclosure



Allegations: UNAUTHORIZED TRADING














Disclosure



Allegations: MISREPRESENTATION; CHURNING; UNAUTHORIZED TRADING; OMISSION OFFACTS





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $280,795.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKEDAMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $167,910.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $50,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFREQUEST HAS BEEN DENIED IN FULL; ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL; OTHER COSTS, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $200.00 JOINTLY AND SEVERALLY; OTHER MONETARYRELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: EXECUTIONS-FAILURE TO EXECUTE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $4,572.00; INTEREST, ASKEDAMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $4,572.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT $199.76; OTHER COSTS, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $125.00






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; SUITABILITY





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $109,000.00; OTHERMONETARY RELIEF, ASKED AMOUNT $0.00; INTEREST, ASKED AMOUNT $0.00;OTHER COSTS, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $93,000.00 JOINTLY AND SEVERALLY; OTHER MONETARYRELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL; INTEREST, RELIEF REQUESTHAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED INFULL; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: UNAUTHORIZED TRADING; MISREPRESENTATION; MANIPULATION; CHURNING





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $243,916.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00; OTHER NON-MONETARY RELIEF, ASKED AMOUNT



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $62,400.00 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARDAMOUNT $12,800.00 JOINTLY AND SEVERALLY; OTHER COSTS, RELIEF REQUESTHAS BEEN DENIED IN FULL; INTEREST, RELIEF REQUEST HAS BEEN DENIED INFULL; OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER NON-MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL,AWARD AMOUNT JOINTLY AND SEVERALLY






Disclosure



Allegations: ACCOUNT RELATED-OTHER














Disclosure



Allegations: SUITABILITY; BRCH OF FIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $31,000.00; INTEREST,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT$5,000.00; OTHER COSTS, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKEDAMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $18,975.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL); PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: UNAUTHORIZED TRADING; OMISSION OF FACTS














Disclosure



Allegations: UNAUTHORIZED TRADING; EXECUTIONS-FAILURE TO EXECUTE




Disputed Product Type: PREFERRED STOCK




Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER COSTS, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$75.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION; OMISSION OF FACTS; ACCOUNT RELATED - FAILURE TOSUPERVISE




Disputed Product Type: COMMON STOCK; WARRANTS/RIGHTS; PREFERRED STOCK










Disclosure



Allegations: UNAUTHORIZED TRADING; BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $50,000.00; ATTORNEY'SFEES, ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; SPECIFICPERFORMANCE, ASKED AMOUNT; SPECIFIC PERFORMANCE, ASKED AMOUNT



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $123,250.00; ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED INFULL; SPECIFIC PERFORMANCE, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL),AWARD AMOUNT; SPECIFIC PERFORMANCE, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT






Disclosure



Allegations: UNAUTHORIZED TRADING; OTHER; MISREPRESENTATION; BRCH OF FIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $0.00; RACKETEERINGINTERSTATE CORRUPTION ORG, ASKED AMOUNT $0.00; INTEREST, ASKEDAMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; TREBLEDAMAGES, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $10,000.00;OTHER COSTS, ASKED AMOUNT $520.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $38,955.00 JOINTLY AND SEVERALLY; RACKETEERINGINTERSTATE CORRUPTION ORG, RELIEF REQUEST HAS BEEN DENIED IN FULL;INTEREST, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL);PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;TREBLE DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL; ATTORNEY'SFEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$10,000.00 JOINTLY AND SEVERALLY; OTHER COSTS, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL), AWARD AMOUNT $520.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: UNAUTHORIZED TRADING; BRCH OF FIDUCIARY DT














Disclosure



Allegations: UNAUTHORIZED TRADING; ACCOUNT RELATED - FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $9,975.00; INTEREST, ASKEDAMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARYDAMAGES, ASKED AMOUNT $0.00; ACTUAL/COMPENSATORY DAMAGES, ASKEDAMOUNT $9,975.00; INTEREST, ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKEDAMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $360.50 JOINTLY AND SEVERALLY; INTEREST, RELIEF HASBEEN AWARDED (PARTIAL OR FULL); ATTORNEY'S FEES, RELIEF REQUEST HASBEEN DENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HASBEEN DENIED IN FULL; ACTUAL/COMPENSATORY DAMAGES, RELIEF REQUEST HASBEEN DENIED IN FULL; INTEREST, RELIEF REQUEST HAS BEEN DENIED IN FULL;ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure








Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $3,533.95; OTHERMONETARY RELIEF, ASKED AMOUNT $2,500.00; ATTORNEY'S FEES, ASKEDAMOUNT $1,000.00; INTEREST, ASKED AMOUNT $0.00; OTHER MONETARY RELIEF,ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $3,533.95 JOINTLY AND SEVERALLY; OTHER MONETARYRELIEF, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT$2,500.00; ATTORNEY'S FEES, RELIEF HAS BEEN AWARDED (PARTIAL OR FULL),AWARD AMOUNT $1,000.00 JOINTLY AND SEVERALLY; INTEREST, RELIEF HAS BEENAWARDED (PARTIAL OR FULL); OTHER MONETARY RELIEF, RELIEF HAS BEENAWARDED (PARTIAL OR FULL), AWARD AMOUNT $150.00 JOINTLY AND SEVERALLY






Disclosure



Allegations: MISREPRESENTATION; UNAUTHORIZED TRADING; ACCOUNT RELATED - FAILURETO SUPERVISE; BRCH OF FIDUCIARY DT





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $2,027,949.00; INTEREST,ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT$4,055,898.00; TREBLE DAMAGES, ASKED AMOUNT $6,083,857.00; OTHER COSTS,ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00;ATTORNEY'S FEES, ASKED AMOUNT $0.00; ACTUAL/COMPENSATORY DAMAGES,ASKED AMOUNT $2,027,949.00; INTEREST, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $278,298.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL); PUNITIVE/EXEMPLARY DAMAGES,RELIEF REQUEST HAS BEEN DENIED IN FULL; TREBLE DAMAGES, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIEDIN FULL; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL OR



FULL), AWARD AMOUNT $493,570.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL)






Disclosure



Allegations: UNAUTHORIZED TRADING; OTHER; ACCOUNT RELATED - FAILURE TO SUPERVISE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $9,218.00; INTEREST, ASKEDAMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; PUNITIVE/EXEMPLARYDAMAGES, ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00; OTHERNON-MONETARY RELIEF, ASKED AMOUNT



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $9,218.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFHAS BEEN AWARDED (PARTIAL OR FULL), AWARD AMOUNT $1,451.83 JOINTLY ANDSEVERALLY; ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED IN FULL;PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEEN DENIED IN FULL;OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHER NON-MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure



Allegations: BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT;MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $190,000.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $1,000,000.00; INTEREST,ASKED AMOUNT $0.00; ATTORNEY'S FEES, ASKED AMOUNT $0.00; OTHER COSTS,ASKED AMOUNT $0.00; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $281,304.97 JOINTLY AND SEVERALLY;PUNITIVE/EXEMPLARY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $100,000.00; INTEREST, RELIEF HAS BEEN AWARDED(PARTIAL OR FULL); ATTORNEY'S FEES, RELIEF REQUEST HAS BEEN DENIED INFULL; OTHER COSTS, RELIEF REQUEST HAS BEEN DENIED IN FULL; OTHERMONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIED IN FULL






Disclosure

















Disclosure



Allegations: ACCOUNT RELATED-NEGLIGENCE; BRCH OF FIDUCIARY DT; MISREPRESENTATION;OTHER














Disclosure



Allegations: MISREPRESENTATION; SUITABILITY; BRCH OF FIDUCIARY DT; EXECUTIONS-FAILURE TO EXECUTE





Relief Sought: ACTUAL/COMPENSATORY DAMAGES, ASKED AMOUNT $81,050.00; INTEREST,ASKED AMOUNT $0.00; OTHER COSTS, ASKED AMOUNT $0.00;PUNITIVE/EXEMPLARY DAMAGES, ASKED AMOUNT $0.00; OTHER NON-MONETARYRELIEF, ASKED AMOUNT; OTHER MONETARY RELIEF, ASKED AMOUNT $0.00



Relief Awarded: ACTUAL/COMPENSATORY DAMAGES, RELIEF HAS BEEN AWARDED (PARTIAL ORFULL), AWARD AMOUNT $39,357.00 JOINTLY AND SEVERALLY; INTEREST, RELIEFREQUEST HAS BEEN DENIED IN FULL; OTHER COSTS, RELIEF REQUEST HAS BEENDENIED IN FULL; PUNITIVE/EXEMPLARY DAMAGES, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER NON-MONETARY RELIEF, RELIEF REQUEST HAS BEENDENIED IN FULL; OTHER MONETARY RELIEF, RELIEF REQUEST HAS BEEN DENIEDIN FULL



Civil – Final

This section provides details regarding a final, civil action as reported by the firm and/or a securities regulator to CRD.The event may include an injunction issued by a foreign or domestic court in the last 10 years in connection withinvestment-related activity, a finding by a domestic or foreign court of a violation of any investment-related statute(s) orregulation(s), or an action dismissed by a domestic or foreign court pursuant to a settlement agreement.

Disclosure

Reporting Source: REGULATOR (U6)Current Status: FINALAllegations: ABOVE NAMED RESPONDENTS, HAVING DENIED ALLEGATIONS OF

VIOLATIONS OF THE INDIANA SECURITIES ACT, HAVE ENTERED INTO ASETTLEMENT AGREEMENT WITH THE PROSECUTING ATTORNEY OFTHE 28TH JUDICIAL CIRCUIT, JOHNSON COUNTY, INDIANA WHEREBYTHEY SHALL DISCONTINUE THE SALES OF SECURITIES WITHINJOHNSON COUNTY, INDIANA, PERMANENTLY, AND SHALL, FROM THISDATE FORWARD, REFRAIN FROM SOLICITATION OF ANY NEWCUSTOMERS FOR THE PURCHASE OF SECURITIES WITHIN JOHNSONCOUNTY, EITHER DIRECTLY OR INDIRECTLY, AND SHALL PROHIBITTHEIR RESPECTIVE AGENTS, ASSIGNS, OR SUCCESSORS IN INTERESTFROM SO SELLING OR OFFERING FOR SALE, ANY SECURITY, ASDEFINED UNDER THE FEDERAL SECURITIES LAWS OR BY THE INDIANASECURITIES DIVISION. FURTHERMORE, STRATTON AND BILTMORESHALL COLLECTIVELY PAY THE SUM OF ONE HUNDRED THOUSANDDOLLARS ($100,000.00) TO THE JOHNSON COUNTY LAWENFORCEMENT FUND AS WELL AS PAY RESTITUTION IN THE SUM OF$228,669.50.

Initiated By: INDIANACourt Details:Date Court Action Filed:Principal Product Type:Other Product Types:Relief Sought:Other Relief Sought:Resolution: ORDERResolution Date: 06/26/1995Sanctions Ordered or ReliefGranted:



Other Sanctions:Sanction Details:



Civil – Final

This section provides details regarding a final, civil action as reported by the firm and/or a securities regulator to CRD.The event may include an injunction issued by a foreign or domestic court in the last 10 years in connection withinvestment-related activity, a finding by a domestic or foreign court of a violation of any investment-related statute(s) orregulation(s), or an action dismissed by a domestic or foreign court pursuant to a settlement agreement.

Disclosure

Reporting Source: REGULATOR (U6)Current Status: FINALAllegations: PERMANENT INJUNCTION ISSUED AGAINST STRATTON OAKMONT BY

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIAInitiated By: ARKANSAS SECURITIES DEPARTMENTCourt Details:Date Court Action Filed:Principal Product Type:Other Product Types:Relief Sought:Other Relief Sought:Resolution: DECISIONResolution Date: 4/28/1995Sanctions Ordered or ReliefGranted:Other Sanctions:Sanction Details: ARKANSAS CODE ANN. 23-42-308(a)(2)(D) PROVIDES THAT THE

ARKANSAS SECURITIES COMMISSIONER MAY SUSPEND OR REVOKEANY REGISTRATION IF THE REGISTRANT BROKER-DEALER ISPERMANENTLY OF TEMPORARILY ENJOINED BY ANY COURT OFCOMPETENT JURISDICTION FROM ENGAGING IN OR CONTINUING ANYCONDUCT OR PRACTICE INVOLVING ANY ASPECT OF THE SECURITIESBUSINESS. ON FEBRUARY 28, 1995, THE UNITED STATES DISTRICTCOURT FOR THE DISTRICT OF COLUMBIA ISSUED A PERMANENTINJUNCTION AGAINST STRATTON OAKMONT FOR VIOLATING THESECURITIES AND EXCHANGE COMMISSION'S MARCH 17, 1994 ORDER"INSTITUTING PUBLIC ADMINISTRATIVE PROCEEDINGS, MAKINGFINDINGS AND IMPOSING REMEDIAL SANCTIONS." ARKANSAS CODEANN. 23-42-308(c) PROVIDES THAT THE COMMISSIONER MAY BY ORDERSUMMARILY SUSPEND THE REGISTRATION OF A BROKER-DEALER



PENDING FINAL DETERMINATION OF ANY PROCEEDING. IF NOHEARING IS REQUESTED WITHIN FIFTEEN (15) DAYS AND NONE ISORDERED BY THE COMMISSIONER, THE ORDER WILL REMAIN INEFFECT UNTIL MODIFIED OR VACATED BY THE COMMISSIONER. NOBUSINESS MAY BE TRANSACTED IN THE STATE OF ARKANSAS DURINGTHE PERIOD OF SUSPENSION. CONTACT: TOM BULL, 501-324-9260



Bankruptcy/Financial Proceeding – Pending

This section provides details regarding a bankruptcy or other financial proceeding that is pending, as reported by the firmand/or a regulator to CRD. The event may include a bankruptcy or SIPC liquidation filed within the last 10 years.

Disclosure

Reporting Source: FirmAction Type: BankruptcyAction Date: 6/12/1997Court:Is action pending?Summary: CORRES. REC'D (JDS# 8009 14997) DISCLOSES A NOTICE TO CUSTOMERS AND

CREDITORS OF STRATTON OAKMONT INC. AND TO ALL OTHER PARTIES IN INTEREST,IN SIPA PROCEEDING NO. 97-8074A (TLB), SECURITIES INVESTOR PROTECTIONCORPORATION, PLAINTIFF, V. STRATTON OAKMONT INC., DEFENDANT, IN UNITEDSTATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK.



Bankruptcy/Financial Proceeding – Pending

This section provides details regarding a bankruptcy or other financial proceeding that is pending, as reported by the firmand/or a regulator to CRD. The event may include a bankruptcy or SIPC liquidation filed within the last 10 years.

Disclosure

Reporting Source: FirmAction Type: LiquidationAction Date: 01/24/1997Court:Is action pending?Summary: 2-6-97-A TRUSTEE HAS BEEN APPOINTED FOR THE SIPC MEMBER: 97-258,

STRATTON OAKMONT, INC 1979 MARCUS AVENUE, STE. 120, LAKE SUCCESS, NY11042 (TRUSTEE APPOINTED 1/24/97, FILING DATE 1/24/97). TRUSTEE: HARVEY R.MILLER, ESQUIRE WEIL, GOTSHAL & MANGES, LLP 767 FIFTH AVENUE, NEW YORK, NY10153-0119.



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