FINRA

FINRA RULES 2010, 2150(A), 3270, NASD RULES 2110, 2330(A), 3030 - LARRY RICHARD GREGORY SERVED AS VICE PRESIDENT AND BOARD MEMBER OF A PURPORTED CHARITABLE FOUNDATION HE MANAGED WITH OTHER NON-REGISTERED PRINCIPALS AND UNBEKNOWNST TO HIS MEMBER FIRM, HE EFFECTED THE TRANSFER OF APPROXIMATELY $400,000 FROM MEMBER FIRM CUSTOMERS (MOST OF WHOM ARE NOW DECEASED) TO THE FOUNDATION AS SUPPOSED DONATIONS; $184,000 OF THAT AMOUNT WAS TRANSFERRED TO THE FOUNDATION BY GREGORY FROM THE BROKERAGE ACCOUNT OF THE SOLE KNOWN SURVIVING DONOR CUSTOMER. FOR ALMOST SEVEN YEARS, GREGORY, IN CONJUNCTION WITH THE OTHER NON-REGISTERED PRINCIPALS, COLLECTIVELY CONVERTED FOR THEIR PERSONAL USE A TOTAL OF $79,444.70 FROM THE FOUNDATION ACCOUNT MAINTAINED AT GREGORY'S MEMBER FIRM THEY CONTROLLED. THE MONEY GENERALLY WAS USED TO FUND THE EDUCATIONS OF THE PRINCIPALS' RELATIVES. GREGORY PERSONALLY CONVERTED A TOTAL OF $26,619.45 OF THAT AMOUNT FOR HIS OWN PERSONAL USE. FOR MORE THAN A DECADE WHILE ASSOCIATED WITH BOTH THE FOUNDATION AND HIS MEMBER FIRM, GREGORY FAILED TO DISCLOSE TO HIS FIRM HIS OFFICER AND DIRECTOR POSITIONS AND HIS ROLE IN A BUSINESS ACTIVITY OUTSIDE THE SCOPE OF HIS RELATIONSHIP WITH HIS FIRM; GREGORY DID NOT DISCLOSE HIS ASSOCIATION WITH THE FOUNDATIONS UNTIL AFTER THE FIRM UNDERTOOK AN INTERNAL REVIEW OF HIS ACTIVITIES RELATED TO THE FOUNDATION. GREGORY ASSISTED AN ELDERLY CUSTOMER IN CAUSING A BANK TO ISSUE HIM A $40,061.48 CHECK AS A GIFT FROM THE CUSTOMER CONTRARY TO HIS FIRM'S WRITTEN SUPERVISORY PROCEDURES THAT REQUIRED ASSOCIATED PERSONS, INCLUDING GREGORY, TO NOTIFY THE FIRM OF, AND RECEIVE APPROVAL FOR ANY NON-DE MINIMIS GIFTS RECEIVED FROM CUSTOMERS; THE PROCEDURES ALSO PLACED AN ANNUAL $100 CAP ON CUSTOMER GIFTS. GREGORY FAILED TO DISCLOSE, AND RECEIVE WRITTEN APPROVAL FOR, THE $40,061.48 GIFT, VIOLATING HIS FIRM'S WRITTEN SUPERVISORY PROCEDURES. AS A RESULT OF HIS VIOLATIONS, GREGORY'S FIRM'S ABILITY TO EFFECTIVELY SUPERVISE OVER SUBJECTS OF REGULATORY IMPORTANCE WAS IMPEDED, INCLUDING, BUT NOT LIMITED TO, ISSUES RELEVANT TO CUSTOMER PROTECTION.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

7/26/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, GREGORY CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.