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Staff from the Colorado Division of Securities (the "Division") allege that Stephen P. Harro and Income Management Company, CRD No. 113682, collectively referred to as Respondents, failed to cure the deficiencies specified in a Staff letter issued on September 28, 2012. Respondents were informed that they could not access a client's account by using the client's own unique identifying information; they needed to maintain written information for each client that is the basis for making any recommendation; and they needed to maintain all trial balances, financial statements (prepared in accordance with generally accepted accounting principles), and internal audit working papers relating to the investment adviser's business as an investment adviser. Staff allege that respondents are in violation of Rules 51-4.8(IA)(X), 51-4.6(IA)(A)(17), and 51-4.6(IA)(A)(6).
Resolution
Order
Sanctions
Respondents agree to fully comply with all action items requested in the Division of Securities (the "Division") deficiency letter issued February 10, 2021 and shall obtain a compliance consultant, approved by the Division, within sixty (60) days from the entry of the Consent Order. The respondents will retain the compliance consultant for a period of two (2) years. If the consultant's compliance services agreement is terminated for any reason during the supervision period, Respondents shall notify the Division in writing within five (5) business days of the termination.
Broker Comment
The firm agreed to remedy deficiencies cited by the Division and to retain a compliance consultant for two years.
Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.
Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.