FINRA

NASD RULES 2110, 3010, MSRB RULE G-27: SIRT WAS A SUPERVISOR IN HIS MEMBER FIRM'S PRIVATE CLIENT SERVICES (PCS) GROUP. IN THAT CAPACITY, SIRT WAS RESPONSIBLE FOR SUPERVISING FIXED INCOME TRANSACTIONS. SOME FIRM CUSTOMERS OF THE PCS GROUP PAID EXCESSIVE MARKUPS ON CERTAIN FIXED INCOME TRANSACTIONS. IN CONNECTION WITH THOSE TRANSACTIONS, SIRT FAILED TO DETECT THE EXCESSIVE MARK-UPS AND FAILED TO REASONABLY ENFORCE THE FIRM'S PROCEDURES RELATED TO FAIR PRICING.

Acceptance, Waiver & Consent(AWC)

Censure

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

$30,000.00

Requalification

WITHOUT ADMITTING OR DENYING THE FINDINGS, SIRT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS CENSURED, FINED $30,000 ($15,000 OF WHICH PERTAINS TO THE VIOLATIONS OF MSRB RULE G-27), AND REQUIRED TO REQUALIFY FOR THE SERIES 24 LICENSE WITHIN 60 DAYS OF THE DATE OF FINRA'S NOTICE OF ACCEPTANCE OF THE AWC.

WITHOUT ADMITTING OR DENYING THE FINDINGS, SIRT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS CENSURED, FINED $30,000 ($15,000 OF WHICH PERTAINS TO THE VIOLATIONS OF MSRB RULE G-27), AND REQUIRED TO REQUALIFY FOR THE SERIES 24 LICENSE WITHIN 60 DAYS OF THE DATE OF FINRA'S NOTICE OF ACCEPTANCE OF THE AWC.