invemed associates llc - finra · doing business as invemed associates llc (212) 421-2500 regulated...

BrokerCheck Report

INVEMED ASSOCIATES LLC

Section Title

Report Summary

Firm History

CRD# 6728

1

6

Firm Profile 2 - 5

Page(s)

Firm Operations 7 - 12

Disclosure Events 13

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CRD# 6728

SEC# 8-18082

Main Office Location

375 PARK AVENUESUITE 2205NEW YORK, NY 10152-0189Regulated by FINRA New York Office

Mailing Address

375 PARK AVENUESUITE 2205NEW YORK, NY 10152-0189

Business Telephone Number

(212) 421-2500

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 2

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in New York on 03/01/1999.

Its fiscal year ends in June.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 4 types of businesses.

This firm is not affiliated with any financial orinvestment institutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 3 Self-Regulatory Organizations• 43 U.S. states and territories

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1©2017 FINRA. All rights reserved. Report about INVEMED ASSOCIATES LLC


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This firm is classified as a limited liability company.

This firm was formed in New York on 03/01/1999.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in June.


SEC#

6728

8-18082

Main Office Location

Mailing Address

Business Telephone Number

Doing business as INVEMED ASSOCIATES LLC

(212) 421-2500

Regulated by FINRA New York Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

INVEMED SECURITIES, INC.

MEMBER

75% or more

No

Domestic Entity

04/1987

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BARAN, JOHN STANLEY

MANAGER/SENIOR VP/ CFO/CCO/SECRETARY

Less than 5%

No

Individual

09/1996

Yes

1563209



Position


Position Start Date

LANGONE, KENNETH GERARD

MANAGER/PRESIDENT

Less than 5%

Individual

07/1974

302133








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

LANGONE, KENNETH GERARD

CHAIRMAN & PRESIDENT

INVEMED SECURITIES, INC.

75% or more

No

Individual

04/1987

Yes

302133



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

03/29/1999Date of Succession:

This firm was previously:

Predecessor SEC#:

INVEMED ASSOCIATES, INC.

8-18859

6728Predecessor CRD#:

Description INVEMED ASSOCIATES, INC. ("INVEMED"), AN EXISTING BROKER-DEALER,UNDERWENT A CORPORATE REORGANIZATION EFFECTIVE THECLOSE MARCH 29, 1999. AS A RESULT OF THIS REORGANIZATION,INVEMED WAS RESTRUCTURED AS A LIMITED LIABILITY COMPANY, ANDWILL OPERATE UNDER THE SAME INVEMED ASSOCIATES LLC ("LLC").THERE WAS NO CHANGE IN THE NATURE OF THE BUSINESS, THESUPERVISORY PERSONNEL, OR THE ULTIMATE OWNERSHIP ANDCONTROL OF THE BUSINESS PREVIOUSLY CONDUCTED BY INVEMEDWHICH NOW IS CONDUCTED BY LLC.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 3 SROs and 43 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 07/03/1974

Self-Regulatory Organization Status Date Effective

FINRA Approved 08/14/1974

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 11/17/1982






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 11/15/1990

Arizona Approved 01/10/1995

California Approved 04/22/1999

Colorado Approved 11/07/1991

Connecticut Approved 12/16/1974

Delaware Approved 01/08/1986

District of Columbia Approved 04/24/1991

Florida Approved 04/27/1983

Georgia Approved 06/17/1985

Hawaii Approved 08/17/1999

Idaho Approved 03/29/1996

Illinois Approved 05/20/1975

Indiana Approved 05/21/1992

Iowa Approved 03/28/1996

Kansas Approved 01/24/1996

Kentucky Approved 05/25/1995

Louisiana Approved 03/25/1996

Maine Approved 01/04/1994

Maryland Approved 01/03/1984

Massachusetts Approved 07/06/1987

Michigan Approved 05/25/1999

Minnesota Approved 09/28/1993

Mississippi Approved 04/25/1995

Missouri Approved 10/28/1992

Nevada Approved 04/12/1996

New Hampshire Approved 01/16/1991

New Jersey Approved 07/13/1983

New Mexico Approved 12/11/1990

New York Approved 01/02/1985

North Carolina Approved 08/23/1982

Ohio Approved 03/15/1984

Oklahoma Approved 10/28/1993

Pennsylvania Approved 09/15/1977

U.S. States &Territories

Status Date Effective

Rhode Island Approved 03/19/1996

South Carolina Approved 04/04/1995

Tennessee Approved 10/23/1990

Texas Approved 07/22/1983

Utah Approved 03/04/1996

Vermont Approved 02/13/1991

Virginia Approved 08/16/1990

Washington Approved 07/21/1993

West Virginia Approved 03/05/1996

Wisconsin Approved 10/22/1992






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 4 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer retailing corporate equity securities over-the-counter

Trading securities for own account

Other - VARIOUS INVESTMENTS IN LIMITED PARTNERSHIPS/CORPORATIONS FOR OWN ACCOUNT.

PAYMENTS RECEIVED FOR BROKERAGE SERVICES RENDERED INCLUDING GIVING INVESTMENT ADVICEAND ARRANGING MEETINGS WTIH CORPORATE EXECUTIVES.






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: NATIONAL FINANCIAL SERVICES LLC

Business Address: 200 SEAPORT BLVDBOSTON, MA 02210

CRD #: 13041

Effective Date: 04/08/2015

Description: INVEMED ASSOCIATES INTRODUCES ITS CUSTOMERS TO NATIONALFINANCIAL SERVICES LLC ON A FULLY DISCLOSED ARRANGEMENT.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing


Business Address: 200 SEAPORT BLVD.BOSTON, MA 02210

CRD #: 13041




Business Address: 200 SEAPORT BLVDBOSTON, MA 02210

CRD #: 13041




Business Address: 200 SEAPORT BLVD.BOSTON, MA 02210

CRD #: 13041








Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is not, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 2 0






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 2

Reporting Source: Regulator

Allegations: NASD CONDUCT RULES 2110 AND 3010, AND NASD MARKETPLACE RULE6955(A) - RESPONDENT INVEMED ASSOCIATES LLC, THROUGH ITSREPORTING AGENT, FAILED TO TIMELY REPORT TO OATS REPORTABLEORDER EVENTS ("ROES"). THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND WITH NASD RULES CONCERNING OATS RULES. .SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDEWRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO OATS RULES; (2) A STATEMENT OF THE SUPERVISORYSTEP(S) TO BE TAKE BY THE IDENTIFIED PERSON(S); (3) A STATEMENT ASTO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) ASTATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDE INTHE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.

Current Status: Final






Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/16/2004

Docket/Case Number: CMS040099

Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES PRODUCT

Allegations: NASD CONDUCT RULES 2110 AND 3010, AND NASD MARKETPLACE RULE6955(A) - RESPONDENT INVEMED ASSOCIATES LLC, THROUGH ITSREPORTING AGENT, FAILED TO TIMELY REPORT TO OATS REPORTABLEORDER EVENTS ("ROES"). THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND WITH NASD RULES CONCERNING OATS RULES. .SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDEWRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO OATS RULES; (2) A STATEMENT OF THE SUPERVISORYSTEP(S) TO BE TAKE BY THE IDENTIFIED PERSON(S); (3) A STATEMENT ASTO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) ASTATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDE INTHE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED.

Resolution Date: 07/16/2004

Resolution:

Other Sanctions Ordered: UNDERTAKING.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED, FINED $8,000, AND REQUIREDTO UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESWITH RESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONSCONCERNING OATS RULES WITHIN 30 BUSINESS DAYS.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $8,000.00

Acceptance, Waiver & Consent(AWC)






WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED, FINED $8,000, AND REQUIREDTO UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESWITH RESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONSCONCERNING OATS RULES WITHIN 30 BUSINESS DAYS.

iReporting Source: Firm

Initiated By: NASD




Docket/Case Number: CMS040099

Principal Product Type: Equity - OTC

Other Product Type(s):

Allegations: NASD CONDUCT RULES 2110 AND 3010, AND NASD MARKETPLACE RULE6955(A)-RESPONDENT INVEMED ASSOCIATES LLC, THROUGH ITSREPORTING AGENT, FAILED TO TIMELY REPORT TO OATS REPORTABLEORDER EVENTS.THE NASD STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS ANDNASD RULES CONCERNING OATS RULES.



Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED, FINED $8,000, ANDREQUESTED TO UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES.


Acceptance, Waiver & Consent(AWC)

Disclosure 2 of 2

i

Reporting Source: Regulator






Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: NY-2082

Principal Product Type:


Allegations:



Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement COMP #NY-2082, FILED 5/31/83, DIST. #12, ALLEGING VIOLATIONS OFARTICLE III, SECTION 1 IF THE RULES OF FAIR PRACTICE -RESPONDENTS MEMBER, KENNETH G. LANGONE, PAUL R. STANDEL ANDCRISTINA D. LAHEY, SOLD UNITS OF A NEW PUBLIC OFFERING WHICHTRADED AT AN IMMEDIATE PREMIUM IN THE SECONDARY MARKET TO ANUMBER OF RESTRICTED ACCOUNTS; RESPONDENTS LANGONE,STANDEL,LAHEY, JAMES T. RAU, GERARD F. BELL AND JAMES R. FRANKENTHALERPURCHASED FOR THEIR OWN ACCOUNTS SHARES OF SAID OFFERING;RESPONDENT ROBERT S. PIRIE PURCHASED THRU THE MEMBER SHARESOFSAID OFFERING FOR HIS OWN ACCOUNT AND THE ACCOUNT OF HISDEPENDENT CHILDREN; AND, RESPONDENT ARTHUR K. CALCAGNINIPURCHASED THRU THE MEMBER FOR HIS OWN ACCOUNT SHARES OFSAIDNEW OFFERING, ALL IN CONTRAVENTION OF THE B/G'S INTERPRETATIONWITH RESPECT TO FREE-RIDING AND WITHHOLDING.****DECISIONRENDERED 9/26/84, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYTHE RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER ISCENSURED, RESPONDENTS MEMBER, LANGONE AND STANDEL ARE FINED$4,000, J&S, LANGONE IS CENSURED AND DIRECTED TO DISGORGE TOTHE ASSOCIATION THE IMPUTED PROFIT OF $12,400, STANDEL ISCENSURED AND DIRECTED TO DISGORGE TO THE ASSOCIATION THEIMPUTED PROFIT OF $12,400, BELL IS CENSURED AND FINED $500 ANDDIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTED PROFIT OF$2,800, FRANKENTHALER IS CENSURED, FINED $500 AND DIRECTED TODISGORGE TO THE ASSOCIATION THE IMPUTED PROFIT OF $1,600,LAHEY IS CENSURED, FINED $1,000 AND DIRECTED TO DISGORGE TO THEASSOCIATION THE IMPUTED PROFIT OF $4,800, RAU IS CENSURED, FINED$500 AND DIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTEDPROFIT OF $2,800, PIRIE IS FINED $400 AND DIRECTED TO DISGORGETO THE ASSOCIATION THE IMPUTED PROFIT OF $9,600, AND CALCAGNINIIS DIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTED PROFITOF$16,000. ALL RIGHTS OF APPEAL AND REVIEW HAVE BEEN WAIVED, THISDECISION WAS FINAL 9/26/84. ****12/3/84, FC# 8909, PAID IN FULL.


Consent






COMP #NY-2082, FILED 5/31/83, DIST. #12, ALLEGING VIOLATIONS OFARTICLE III, SECTION 1 IF THE RULES OF FAIR PRACTICE -RESPONDENTS MEMBER, KENNETH G. LANGONE, PAUL R. STANDEL ANDCRISTINA D. LAHEY, SOLD UNITS OF A NEW PUBLIC OFFERING WHICHTRADED AT AN IMMEDIATE PREMIUM IN THE SECONDARY MARKET TO ANUMBER OF RESTRICTED ACCOUNTS; RESPONDENTS LANGONE,STANDEL,LAHEY, JAMES T. RAU, GERARD F. BELL AND JAMES R. FRANKENTHALERPURCHASED FOR THEIR OWN ACCOUNTS SHARES OF SAID OFFERING;RESPONDENT ROBERT S. PIRIE PURCHASED THRU THE MEMBER SHARESOFSAID OFFERING FOR HIS OWN ACCOUNT AND THE ACCOUNT OF HISDEPENDENT CHILDREN; AND, RESPONDENT ARTHUR K. CALCAGNINIPURCHASED THRU THE MEMBER FOR HIS OWN ACCOUNT SHARES OFSAIDNEW OFFERING, ALL IN CONTRAVENTION OF THE B/G'S INTERPRETATIONWITH RESPECT TO FREE-RIDING AND WITHHOLDING.****DECISIONRENDERED 9/26/84, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYTHE RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER ISCENSURED, RESPONDENTS MEMBER, LANGONE AND STANDEL ARE FINED$4,000, J&S, LANGONE IS CENSURED AND DIRECTED TO DISGORGE TOTHE ASSOCIATION THE IMPUTED PROFIT OF $12,400, STANDEL ISCENSURED AND DIRECTED TO DISGORGE TO THE ASSOCIATION THEIMPUTED PROFIT OF $12,400, BELL IS CENSURED AND FINED $500 ANDDIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTED PROFIT OF$2,800, FRANKENTHALER IS CENSURED, FINED $500 AND DIRECTED TODISGORGE TO THE ASSOCIATION THE IMPUTED PROFIT OF $1,600,LAHEY IS CENSURED, FINED $1,000 AND DIRECTED TO DISGORGE TO THEASSOCIATION THE IMPUTED PROFIT OF $4,800, RAU IS CENSURED, FINED$500 AND DIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTEDPROFIT OF $2,800, PIRIE IS FINED $400 AND DIRECTED TO DISGORGETO THE ASSOCIATION THE IMPUTED PROFIT OF $9,600, AND CALCAGNINIIS DIRECTED TO DISGORGE TO THE ASSOCIATION THE IMPUTED PROFITOF$16,000. ALL RIGHTS OF APPEAL AND REVIEW HAVE BEEN WAIVED, THISDECISION WAS FINAL 9/26/84. ****12/3/84, FC# 8909, PAID IN FULL.

iReporting Source: Firm

Initiated By: NASD


Civil and Administrative Penalt(ies) /Fine(s)



Docket/Case Number: NY-2082

Principal Product Type: Equity - OTC


Allegations: VIOLATION OF NASD BOARD OF GOVERNOR'S INTERPRETATION OF FREE-RIDING AND WITHHOLDING UNDER ARTICLE III, SECTION I OF THE RULESOF FAIR PRACTICE IN CONNECTION WITH THE UNDERWRITING OF VITALMETRICS, INC.


Appealed To and Date AppealFiled:

NASD


Resolution:


Decision & Order of Offer of Settlement






Other Sanctions Ordered:

Sanction Details: INVEMED ASSOCIATES, INC. WAS CENSURED, FINED AND PAID (JOINTLYAND SEVERALLY WITH KENNETH LANGONE) IN THE AMOUNT OF $4,000.

Firm Statement INVEMED ASSOCIATES, INC. RECEIVED CLEARANCE FROM VITAL METRICS,INC.'S ATTORNEYS (WHO HAD DISCUSSIONS WITH THE NASD)THATEMPLOYEES COULD PARTICIPATE IN THE ORIGINAL UNDERWRITING ASLONG AS THIS FACT WAS REFLECTED IN THE PROSPECTUS. HOWEVER,THE NASD SUBSEQUENTLY PROPOSED PENALTIES AS WELL ASDISGORGEMENT OF THE IMPUTED PROFITS.







End of Report

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