FINRA

FINRA RULES 2010, 8210, NASD RULES 2110, 3030, 3040: CARPENTER SOLD PROMISSORY NOTES AND INVESTMENTS IN A GOLD MINE AND CONDOMINIUM/HOTEL DEVELOPMENT TO CUSTOMERS OF HIS MEMBER FIRM AND AN AFFILIATED CREDIT UNION WITHOUT NOTIFYING THE FIRM OR OBTAINING FIRM APPROVAL FOR THE TRANSACTIONS. CARPENTER WAS REQUIRED TO FILL OUT AN "OUTSIDE BUSINESS ACTIVITIES" FORM AND SUBMIT IT TO HIS SUPERVISOR AND THE FIRM'S COMPLIANCE DEPARTMENT BEFORE ENGAGING IN THE OUTSIDE BUSINESS. CARPENTER FAILED TO NOTIFY THE FIRM OR OBTAIN APPROVAL FOR A LIMITED LIABILITY CORPORATION THAT HE ESTABLISHED AND OPERATED, WHICH PROVIDED FINANCIAL MANAGEMENT SERVICES TO THE PUBLIC AND THROUGH WHICH HE ENGAGED IN PRIVATE SECURITIES TRANSACTIONS AWAY FROM HIS FIRM. THE PROMISSORY NOTES AND GOLD MINE AND CONDOMINIUM/HOTEL DEVELOPMENT INVESTMENTS WERE PROCESSED THROUGH CARPENTER'S LIMITED LIABILITY CORPORATION. IN ADDITION, CARPENTER FAILED TO RESPOND TO FINRA REQUESTS FOR INFORMATION AND TESTIMONY.

Decision

Bar (Permanent)

All Capacities

Indefinite

1/12/2012

DEFAULT DECISION RENDERED DECEMBER 15, 2011 WHEREIN CARPENTER IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FAILING TO RESPOND TO FINRA REQUESTS FOR INFORMATION AND TESTIMONY, IN VIOLATION OF FINRA RULES 2010 AND 8210. IN LIGHT OF THE BAR, NO ADDITIONAL SANCTIONS ARE IMPOSED FOR ENGAGING IN PRIVATE SECURITIES TRANSACTIONS WITHOUT NOTIFYING HIS MEMBER FIRM IN ADVANCE, IN VIOLATION OF NASD RULES 2110 AND 3040, OR FAILING TO DISCLOSE HIS OUTSIDE BUSINESS ACTIVITIES TO HIS FIRM, IN VIOLATION OF NASD RULES 2110 AND 3030. THE DECISION IS FINAL JANUARY 12, 2012.