Commissioner of Securities of the State of Hawaii

Pang demonstrated his unworthiness as an agent and investment adviser representative when, while acting in those registered capacities for BFC, Pang borrowed money from 3 IA clients, totaling $155,000. Pang is subject to discipline because on 9/12/2014, FINRA entered an order barring Pang from association with all FINRA members in all capacities. ]

Stipulation and Consent

Bar (Permanent)

General Securities

Permanent

6/21/2017

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

$10,000.00

FINRA

WITHOUT ADMITTING OR DENYING THE FINDINGS, PANG CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT HE BORROWED MONEY FROM THREE CUSTOMERS UNDER CIRCUMSTANCES PROHIBITED BY FINRA RULES. THE FINDINGS STATED THAT AT THE TIME OF EACH LOAN, PANG'S MEMBER FIRM'S PROCEDURES REQUIRED WRITTEN NOTICE TO AND APPROVAL FROM THE FIRM'S COMPLIANCE DEPARTMENT BEFORE ENTERING INTO ANY LENDING ARRANGEMENT WITH A CLIENT, UNLESS THE CLIENT WAS A FAMILY MEMBER OR A FINANCIAL INSTITUTION IN THE LENDING BUSINESS. NEITHER OF THESE EXCEPTIONS APPLIED TO THE CUSTOMERS. NEVERTHELESS, PANG ENTERED INTO THE LOANS WITHOUT PROVIDING NOTICE TO OR RECEIVING APPROVAL FROM THE FIRM. PANG COMPLETED AN ANNUAL COMPLIANCE QUESTIONNAIRE IN WHICH HE FALSELY ANSWERED "NO" TO THE QUESTION, "HAVE YOU BORROWED OR LOANED MONEY OR SECURITIES FROM OR TO ANY CLIENT?" THE FINDINGS ALSO STATED THAT PANG REFUSED TO PROVIDE INFORMATION REQUESTED BY FINRA STAFF IN CONNECTION WITH AN INVESTIGATION CONCERNING LOANS BETWEEN PANG AND HIS CUSTOMERS.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

9/12/2014