FINRA

FINRA RULES 2010, 8210, NASD RULES 2110, 2370: IN APRIL 2006, VANBEENEN BORROWED $240,000 FROM HIS MEMBER FIRM'S CUSTOMER, IN ORDER TO PURCHASE REAL ESTATE. HOWEVER, THE FIRM'S WRITTEN PROCEDURES PROHIBITED REGISTERED REPRESENTATIVES FROM OBTAINING LOANS FROM CUSTOMERS. THE CUSTOMER IS ALSO NOT AN IMMEDIATE FAMILY MEMBER OF VANBEENEN AND WAS NOT REGULARLY ENGAGED IN THE BUSINESS OF PROVIDING CREDIT, FINANCING, OR LOANS, OR REGULARLY ARRANGING OR EXTENDING CREDIT. THE CUSTOMER WAS ALSO NOT REGISTERED WITH A FINRA MEMBER FIRM AND THE LOAN TO VANBEENEN WAS NOT BASED UPON A BUSINESS OR PERSONAL RELATIONSHIP THAT THE CUSTOMER MAINTAINED WITH VANBEENEN OUTSIDE OF THE BROKER-CUSTOMER RELATIONSHIP. ON OR ABOUT NOVEMBER 28, 2007, WHILE EMPLOYED WITH THE FIRM AND ENGAGED IN AN OUTSIDE BUSINESS ACTIVITY, VANBEENEN KNOWINGLY MADE FALSE STATEMENTS TO A FINANCIAL INSTITUTION FOR THE PURPOSE OBTAINING A MORTGAGE ON CERTAIN REAL ESTATE. ON FEBRUARY 22, 2012, IN A UNITED STATES DISTRICT COURT, VANBEENEN PLEADED GUILTY TO FALSE STATEMENTS TO A BANK, A FELONY, IN CONNECTION WITH THIS CONDUCT. IN AN EMAIL DATED MAY 9, 2012 AND A LETTER DATED MAY 14, 2012, FINRA REQUESTED THAT VANBEENEN PROVIDE ON-THE-RECORD TESTIMONY ON MAY 18, 2012, AND PROVIDE INFORMATION REGARDING AN INVESTIGATION OF HIS CONDUCT WHILE EMPLOYED AT THE FIRM. ON OR ABOUT MAY 15, 2012, VANBEENEN INFORMED FINRA THAT HE WOULD NOT APPEAR ON MAY 18, 2012 TO PROVIDE TESTIMONY AND THAT HE WOULD NOT APPEAR FOR TESTIMONY ON ANY FUTURE DATE. VANBEENEN FAILED TO APPEAR ON MAY 18, 2012 TO PROVIDE TESTIMONY AND FAILED TO PROVIDE INFORMATION AS REQUESTED BY FINRA.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

6/15/2012

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