FINRA

FINRA RULES 2010, 3270, 8210, NASD RULES 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(1)(D): ROMAN ENGAGED IN BUSINESS ACTIVITIES OUTSIDE THE SCOPE OF HIS RELATIONSHIP WITH HIS MEMBER FIRMS, WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS FIRMS OR RECEIVING HIS FIRMS' WRITTEN APPROVAL. ROMAN DISSEMINATED SALES LITERATURE CONTAINING INFORMATION THAT DID NOT COMPLY WITH FINRA'S STANDARDS OF COMMUNICATION WITH THE PUBLIC. WITHOUT FIRM APPROVAL, ROMAN SOLICITED INVESTMENTS VIA EMAIL AND DISTRIBUTED A MARKETING BROCHURE THAT WAS INCOMPLETE, MISLEADING, FAILED TO PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS REGARDING THE INVESTMENT, AND MADE EXAGGERATED AND UNWARRANTED CLAIMS AND FORECASTS. ROMAN FAILED TO PROVIDE FINRA WITH REQUESTED DOCUMENTS AND INFORMATION.

Decision

Bar (Permanent)

All Capacities

Indefinite

12/25/2012

DEFAULT DECISION RENDERED NOVEMBER 27, 2012 WHEREIN ROMAN IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FAILING TO PROVIDE DOCUMENTS AND INFORMATION, IN VIOLATION OF FINRA RULES 2010 AND 8210. NO ADDITIONAL SANCTION IS IMPOSED FOR ROMAN'S FAILURE TO PROVIDE PRIOR WRITTEN NOTICE OF AN OUTSIDE BUSINESS ACTIVITY, IN VIOLATION OF FINRA RULES 2010 AND 3270. THE CHARGES OF FAILING TO PROVIDE PRIOR WRITTEN NOTICE OF ANOTHER OUTSIDE BUSINESS ACTIVITY, IN VIOLATION OF FINRA RULES 2010 AND 3270, AND FAILING TO COMPLY WITH THE STANDARDS OF COMMUNICATIONS WITH THE PUBLIC, IN VIOLATION OF FINRA RULE 2010 AND NASD RULE 2210, ARE DISMISSED. THE DECISION IS FINAL DECEMBER 25, 2012.