FLORIDA OFFICE OF FINANCIAL REGULATION

CONDUCTED INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE BENEFIT OF LAWFUL REGISTRATION.

Order

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

$20,000.00

ON 07/13/2015, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE 7/7/2015 STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF ALAN WILLARD KIRCHNER. THROUGH COUNSEL, KIRCHNER COOPERATED WITH THE OFFICE AND INDICATED THE LACK OF REGISTRATION WAS THE RESULT OF AN OVERSIGHT. THE OFFICE FOUND AND MR. KIRCHNER STIPULATED THAT HE ENGAGED IN INVESTMENT ADVISORY BUSINESS WITHIN FLORIDA WITHOUT THE BENEFIT OF LAWFUL REGISTRATION PURSUANT TO SECTION 517.12(4), F.S. MR. KIRCHNER AGREED TO CEASE AND DESIST FROM ANY VIOLATION AND TO HENCEFORTH STRICTLY COMPLY WITH, ALL PROVISIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES PROMULGATED THEREUNDER; AND TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $20,000. THE OFFICE AGREED TO APPROVE MR. KIRCHNER'S APPLICATION AS AN ASSOCIATED PERSON (RA) WITH CRAWFORD INVESTMENT COUNSEL EFFECTIVE 7/13/2015.

IT WAS BROUGHT TO THE FIRM'S ATTENTION AFTER MR. KIRCHNER LEFT BY [CUSTOMER] THAT MR. KIRCHNER PURCHASED OPTIONS AND SOLD SECURITIES WITHOUT AUTHORIZATION, RESULTING IN LOSSES OF APPROXIMATELY $8,800.00. MERRILL LYNCH INVESTIGATED THE ALLEGATIONS.

$8,800.00

$13,750.00

MERRILL LYNCH PAID THE CUSTOMER $13,750.00 FOR SETTLEMENT. MR. KIRCHNER DID NOT CONTRIBUTE NOT PROVIDED