Initiated By
FINRA
Allegations
ARTICLE V, SECTION 2(C) OF FINRA BY-LAWS, FINRA RULES 2010, 8210, NASD RULES 2110, 3030, 3040, INTERPRETATIVE MATERIAL 1000-1: WHILE REGISTERED WITH A MEMBER FIRM, VERCNOCKE ENGAGED IN THE SOLICITATION AND SALE OF UNREGISTERED PROMISSORY NOTES WITHOUT WRITTEN NOTIFICATION TO OR APPROVAL BY HIS FIRM. VERCNOCKE ALSO ENGAGED IN OUTSIDE BUSINESS ACTIVITIES WITHOUT PROVIDING WRITTEN NOTICE TO OR OBTAINING APPROVAL FROM HIS FIRM. FURTHER, VERCNOCKE WILLFULLY FAILED TO DISCLOSE AND AMEND HIS FORM U4 WITH MATERIAL INFORMATION. IN ADDITION, VERCNOCKE FAILED TO RESPOND TO FINRA REQUESTS FOR INFORMATION AND DOCUMENTS AND FAILED TO APPEAR FOR TESTIMONY.
Resolution
Decision
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Start Date
8/11/2011
Regulator Statement
DEFAULT DECISION RENDERED JULY 14, 2011 WHEREIN VERCNOCKE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FAILING TO RESPOND TO REQUESTS FOR INFORMATION AND TESTIMONY, IN VIOLATION OF FINRA RULES 8210 AND 2010, AND WILLFULLY FAILING TO DISCLOSE MATERIAL INFORMATION ON A FORM U4, IN VIOLATION OF NASD RULE 2110, INTERPRETATIVE MATERIAL 1000-1, AND ARTICLE V, SECTION 2 OF FINRA'S BY-LAWS. THE DECISION INCLUDES A FINDING THAT VERCNOCKE WILLFULLY FAILED TO DISCLOSE A MATERIAL FACT ON A FORM U4, AND THAT UNDER SECTION 15(B)(4)(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ARTICLE III, SECTION 4 OF THE FINRA BY-LAWS, MAKES HIM SUBJECT TO STATUTORY DISQUALIFICATION WITH RESPECT TO ASSOCIATION WITH A MEMBER. IN LIGHT OF THE BARS, NO ADDITIONAL SANCTIONS ARE IMPOSED FOR FAILING TO DISCLOSE OUTSIDE BUSINESS ACTIVITIES, IN VIOLATION OF NASD RULES 3030 AND 2110. THE CHARGE OF ENGAGING IN PRIVATE SECURITIES TRANSACTIONS WITHOUT FIRM APPROVAL, IN VIOLATION OF NASD RULES 3040 AND 2110, WAS DISMISSED. THE DECISION IS FINAL AUGUST 11, 2011.