FINRA

WILLFULLY VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 10B-5 THEREUNDER, VIOLATED NASD RULES 2110, 2120, 2310, 3040 - KEVIN SETH BALTIMORE MADE FRAUDULENT AND UNSUITABLE RECOMMENDATIONS TO CUSTOMERS, INDUCING THEM TO INVEST IN A COMMERCIAL PAPER NOTE WHICH WAS A FRAUDULENT PRIVATE PLACEMENT PURPORTEDLY FOR ACCREDITED INVESTORS PURSUANT TO REGULATION D UNDER THE SECURITIES ACT OF 1933. CUSTOMERS INVESTED A TOTAL OF $138,000 IN THE NOTE. BALTIMORE ALSO RECOMMENDED THE NOTE INVESTMENT TO ANOTHER CLIENT OF ONE OF HIS MEMBER FIRMS, WHO INVESTED IN THE OFFERING BUT WAS NOT AN ACCREDITED INVESTOR. BALTIMORE HAD NO REASONABLE GROUNDS FOR BELIEVING THE CUSTOMERS' PURCHASE OF THE NOTE WAS SUITABLE GIVEN THEIR FINANCIAL CONDITION AND THAT THEY WERE NOT ACCREDITED INVESTORS AS DEFINED IN RULE 501 OF REGULATION D UNDER THE SECURITIES ACT OF 1933. BALTIMORE MADE MATERIALLY MISLEADING STATEMENTS AND OMISSIONS OF FACT WHEN RECOMMENDING THE INVESTMENT, INCLUDING MISREPRESENTING THE TYPE OF BUSINESS IN WHICH THE ISSUER WAS ENGAGED AND MISREPRESENTING THE USE OF PROCEEDS TO BE RAISED BY THE NOTE, AND FAILING TO DISCLOSE THAT THE ISSUER WAS A SHELL COMPANY WITH NO SIGNIFICANT BUSINESS. BALTIMORE INTENTIONALLY WITHHELD FROM HIS MEMBER FIRMS THAT HE WAS ENGAGED IN OUTSIDE SECURITIES TRANSACTIONS AND RECOMMENDED THE PURCHASE OF THE NOTE WITHOUT THE APPROVAL OR KNOWLEDGE OF THE FIRMS. BALTIMORE PARTICIPATED IN PRIVATE SECURITIES TRANSACTIONS WITHOUT PROVIDING WRITTEN NOTICE DESCRIBING IN DETAIL THE PROPOSED TRANSACTIONS, HIS ROLE THEREIN AND STATING WHETHER HAD RECEIVED, OR WOULD RECEIVE, SELLING COMPENSATION IN CONNECTION WITH THE TRANSACTIONS.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

12/9/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, BALTIMORE CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. THIS SETTLEMENT INCLUDES A FINDING THAT BALTIMORE WILLFULLY VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER. PURSUANT TO ARTICLE III, SECTION 4 OF FINRA'S BY-LAWS, THIS MAKES HIM SUBJECT TO A STATUTORY DISQUALIFICATION WITH RESPECT TO ASSOCIATION WITH A MEMBER.

NYSE DIVISION OF ENFORCEMENT

**1/5/1999**STIPULATION:CONSENT TO PENALTY FILED BY THE NYSE DIVISION OF ENFORCEMENT AND PENDING. WITH OUT ADMITTING OR DENYING GUILT, BALTIMORE CONSENTED TO: A. A FINDING BY THE HEARING PANEL THAT HE VIOLATED EXCHANGE RULE 346(b) IN THAT HE ENGAGED IN AN OUTSIDE BUSINESS WITHOUT OBTAINING THE PRIOR WRITTEN CONSENT OF HIS MEMBER FIRM EMPLOYER; B.THE IMPOSITION BY THE EXCHANGE OF:1. A CENSURE; 2. A SUSPENSION FROM MEMBERSHIP, ALLIED MEMBERSHIP, APPROVED PERSON STATUS AND EMPLOYMENT OR ASSOCIATION IN ANY CAPACITY WITH ANY MEMBER OR MEMBER ORGANIZATION FOR ONE MONTH;AND 3. A FINEOF $2,500.

Stipulation and Consent

Monetary/Fine

$2,500.00

Censure

Suspension

**2/11/1999** DECISION 99-5 ISSUED BY NYSE HEARING PANEL ON FEBRUARY 11, 1999. VIOLATED EXCHANGE RULE 346(b) BY ENGAGING IN OUTSIDE BUSINESS ACTIVITY WITHOUT EMPLOYER CONSENT--CONSENT TO CENSURE, ONE MONTH SUSPENSION AND $2,500 FINE.

MR. BALTIMORE STATES: WITHOUT ADMITTING OR DENYING ANY FACTS OR CONCLUSIONS CONTAINED IN THE DECISION AND WITHOUT ADMITTING OR DENYING GUILT, MR. BALTIMORE CONSENTED TO THE AFOREMENTIONED PENALTY.