FINRA

NASD RULES 2110, 3030, 3040: KENT PARTICIPATED IN PRIVATE SECURITIES TRANSACTIONS, RECEIVED COMPENSATION FOR HIS PARTICIPATION, FAILED TO PROVIDE HIS MEMBER FIRM WITH PRIOR WRITTEN NOTICE OF HIS PROPOSED PARTICIPATION IN THESE TRANSACTIONS, AND FAILED TO RECEIVE PRIOR WRITTEN APPROVAL FROM THE FIRM. KENT, WHILE ASSOCIATED WITH HIS MEMBER FIRM, ENGAGED IN OUTSIDE BUSINESS ACTIVITIES THROUGH OUTSIDE EMPLOYMENT WITH A COMPANY AND FAILED TO PROVIDE THE FIRM WITH PROMPT WRITTEN NOTICE OF HIS OUTSIDE BUSINESS ACTIVITIES WITH AND ON BEHALF OF THIS COMPANY. KENT SOLICITED NON-SECURITIES INVESTMENTS IN A COMPANY FROM THE FIRM'S CUSTOMERS, RECEIVED COMPENSATION FROM THE COMPANY, AND FAILED TO PROVIDE HIS FIRM WITH PROMPT WRITTEN NOTICE OF THIS OUTSIDE BUSINESS ACTIVITIES. KENT NEGLIGENTLY FAILED TO ADVISE THE COMPANY'S INVESTORS AND THE FIRM'S CUSTOMERS OF MATERIAL FACTS CONCERNING THE COMPANY AND HIS INVOLVEMENT WITH THE SAME.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

7/15/2009

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

BREACH OF FIDUCIARY DUTIES; UNSUITABILITY; AND BREACH OF DUTY OF DUE CARE.

$461,231.12

FINRA

KENT FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

Other

Suspension

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS AND FINRA RULE 9554, KENT'S FINRA REGISTRATION IS SUSPENDED MAY 13, 2009 FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

FINRA

KENT FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

Other

Suspension

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS AND NASD RULE 9554, KENT'S FINRA REGISTRATION IS SUSPENDED AUGUST 20, 2008 FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

CLAIMANT ALLEGED THAT FORMER REPRESENTATIVE KENT INFLUENCED HER TO PURCHASE SEVERAL INVESTMENTS IN A REAL ESTATE DEVELOPMENT COMPANY DURING A PERIOD FROM NOVEMBER 2004 TO THE FALL OF 2005

$245,344.30

$418,468.00

SECURITIES - FRAUD OR DECEIT IN VIOLATION OF §§ 11-51-501(1)(C) AND 11-51-603(1) OF THE COLORADO REVISED STATUTES

Pled guilty

THEFT - $20,000 OR MORE IN VIOLATION OF 18-4-401(1)(B)(2)(D) OF THE COLORADO REVISED STATUTES

Dismissed

SECURITIES - MAKING UNTRUE STATEMENT IN VIOLATION OF §§ 11-51-501(1)(C) AND 11-51-603(1) OF THE COLORADO REVISED STATUTES

Dismissed

UNSUITABILITY;NEGLIGENCE;BREACH OF FIDUCIARY DUTIES;COMMON LAW FRAUD;NEGLIGENT MISREPRESENTATION

$325,000.00

$482,268.00

COMPLAINANTS ALLEGE THAT IN MAY THROUGH NOVEMBER 2005, REISTERED REPRESENTATIVE RECOMMENDED UNSUITABLE INVESTMENTS IN A REAL ESTATE DEVELOPMENT COMPANY IN BREACH OF HIS FIDUCIARY OBLIGATIONS

$392,749.49

$283,744.00