NEW HAMPSHIRE

VILLANI FAILED TO PROVIDE DOCUMENTS REQUESTED BY EXAMINER. VILLANI ENTERED INTO AWC WITH FINRA ON JUNE 21, 2011 IN WHICH FINRA ALLEGED VILLANI CONCEALED OUTSIDE BUSINESS ACTIVITY FROM HER MEMBER FIRM AND MADE FALSE REPRESENTATIONS TO FINRA. AS A RESULT OF THE AWC, VILLANI IS PERMANENTLY BARRED FROM ASSOCIATION WITH A FINRA MEMBER FIRM.

Order

Bar (Permanent)

ALL CAPACITIES

PERMANENT

4/4/2012

Cease and Desist

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

$17,500.00

Revocation

N/A

FINRA

FINRA RULE 2010, NASD RULES 2110, 3030: VILLANI ENGAGED IN OUTSIDE BUSINESS ACTIVITIES WITHOUT PROVIDING PROMPT WRITTEN NOTICE OF THOSE ACTIVITIES TO HER MEMBER FIRM. VILLANI'S INVOLVEMENT WITH THE OUTSIDE COMPANY CONSTITUTED BUSINESS ACTIVITIES OUTSIDE THE SCOPE OF HER RELATIONSHIP WITH THE FIRM. VILLANI, HOWEVER, DID NOT GIVE PROMPT WRITTEN NOTICE, OR ANY NOTICE, TO THE FIRM REGARDING THOSE ACTIVITIES. VILLANI ALSO ACTED TO CONCEAL HER OUTSIDE BUSINESS ACTIVITIES FROM THE FIRM. FOR EXAMPLE, ON FIRM OUTSIDE BUSINESS ACTIVITY DISCLOSURE REPORTS, SHE CLAIMED THAT SHE WAS NOT ENGAGED IN ANY SUCH ACTIVITIES. MOREOVER, WHEN INTERVIEWED BY THE FIRM, VILLANI DENIED THE EXISTENCE OF THE COMPANY AND INSISTED THAT SHE HAD NOT ENGAGED IN CONDUCT THAT CONSTITUTED OUTSIDE BUSINESS ACTIVITIES. THESE CLAIMS WERE FALSE.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

6/20/2011

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