| RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC |
NFA 11BCC00009 |
NFA ID: 0259174 |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | 10/25/2011 | | 0079445 | DHOLAKIA, ALAKESH P | 08/18/2011 | | 0235486 | GINSBERG, RANDOLPH JACOB | 10/25/2011 | | 0098246 | JENKINS, JEFFREY BERNARD | 08/18/2011 | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | 10/25/2011 | | 0196824 | WECHSLER, JEANNE RUTH | |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | • C.R.2-8(a) - GRANT OF DISCRETION MUST BE WRITTEN | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | 0079445 | DHOLAKIA, ALAKESH P | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-30 - FAIL TO OBTAIN CUSTOMER INFO | | | | • C.R.2-8(a) - GRANT OF DISCRETION MUST BE WRITTEN | | 0235486 | GINSBERG, RANDOLPH JACOB | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0098246 | JENKINS, JEFFREY BERNARD | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | • C.R.2-30 - FAIL TO OBTAIN CUSTOMER INFO | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • BLAW301(b) - REGISTRATION OF APS AS ASSOCIATES | | | | • C.R.2-8(a) - GRANT OF DISCRETION MUST BE WRITTEN | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0196824 | WECHSLER, JEANNE RUTH | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-8(a) - GRANT OF DISCRETION MUST BE WRITTEN |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE | | 0079445 | DHOLAKIA, ALAKESH P | • BUSINESS CONDUCT COMMITTEE | | 0235486 | GINSBERG, RANDOLPH JACOB | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE | | 0098246 | JENKINS, JEFFREY BERNARD | • BUSINESS CONDUCT COMMITTEE | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE | | 0196824 | WECHSLER, JEANNE RUTH | • BUSINESS CONDUCT COMMITTEE |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING | | 0079445 | DHOLAKIA, ALAKESH P | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING | | | | • SALES PRACTICE | | 0235486 | GINSBERG, RANDOLPH JACOB | • GENERAL CONDUCT | | 0098246 | JENKINS, JEFFREY BERNARD | • GENERAL CONDUCT | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING | | | | • REGISTRATION | | | | • SALES PRACTICE | | 0196824 | WECHSLER, JEANNE RUTH | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | • TEMPORARY WITHDRAWAL FROM PRINCIPAL STATUS 6 MTHS | 10/18/2011 | | | | • FINE (CONTINGENT) $10000 | 10/18/2011 | | | | • TEMPORARY WITHDRAWAL FROM NFA ASSOCIATE MEMBERSHIP 6 MTHS | 10/18/2011 | | | | • REQUIRED TO TAPE RECORD 1 YRS | 10/18/2011 | | | | • TEMPORARY WITHDRAWAL FROM NFA MEMBERSHIP 6 MTHS | 10/18/2011 | | 0079445 | DHOLAKIA, ALAKESH P | • PERMANENT BAR FROM PRINCIPAL STATUS | 08/03/2011 | | | | • PERMANENT BAR FROM NFA MEMBERSHIP | 08/03/2011 | | | | • PERMANENT BAR FROM NFA ASSOCIATE MEMBERSHIP | 08/03/2011 | | 0235486 | GINSBERG, RANDOLPH JACOB | • TEMPORARY WITHDRAWAL FROM NFA ASSOCIATE MEMBERSHIP 18 MTHS | 10/18/2011 | | | | • OTHER--SEE NARRATIVE | 10/18/2011 | | | | • REQUIRED TO TAPE RECORD 1 YRS | 10/18/2011 | | | | • TEMPORARY WITHDRAWAL FROM PRINCIPAL STATUS 18 MTHS | 10/18/2011 | | | | • TEMPORARY WITHDRAWAL FROM NFA MEMBERSHIP 18 MTHS | 10/18/2011 | | | | • FINE (CONTINGENT) $5000 | 10/18/2011 | | 0098246 | JENKINS, JEFFREY BERNARD | • WITHDRAW PRINCIPAL STATUS | 08/03/2011 | | | | • WITHDRAW FROM NFA ASSOCIATE MEMBERSHIP | 08/03/2011 | | | | • TEMPORARY BAR FROM PRINCIPAL STATUS 3 YRS | 08/03/2011 | | | | • TEMPORARY BAR FROM NFA MEMBERSHIP 3 YRS | 08/03/2011 | | | | • REQUIRED TO TAPE RECORD 1 YRS | 08/03/2011 | | | | • FINE (CONTINGENT) $10000 | 08/03/2011 | | | | • TEMPORARY BAR FROM NFA ASSOCIATE MEMBERSHIP 3 YRS | 08/03/2011 | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | • WITHDRAW FROM MEMBERSHIP | 10/18/2011 | | | | • PERMANENT BAR FROM NFA ASSOCIATE MEMBERSHIP | 10/18/2011 | | | | • PERMANENT BAR FROM PRINCIPAL STATUS | 10/18/2011 | | | | • PERMANENT BAR FROM NFA MEMBERSHIP | 10/18/2011 |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
ANSWER:
On June 14, 2011, Connolly filed an Answer to the Complaint in which he denied the material allegations contained therein.
DECISION:
On October 10, 2011, pursuant to a settlement offer submitted by Connolly, he was ordered to withdraw from NFA membership, associate membership and principal status within fifteen days and not apply for NFA membership, associate membership or principal status for six months from the date of his withdrawal. During the six-month period, he may not act in any capacity requiring registration nor act as a principal of an NFA Member.
If, after expiration of the six-month period, Connolly applies for NFA membership, associate membership or seeks to become a principal of an NFA Member, then he was ordered to pay a $10,000 fine, due and payable at the same time he applies for NFA membership, associate membership or becomes a principal of an NFA Member. Any future application made by Connolly for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless and until his fine has been paid in full.
If Connolly again becomes an NFA Member or Associate, he was ordered to tape record, for one year, all conversations between himself and existing or potential customers; retain the tapes for one year from the date they are created; and make the tapes available to NFA. The one-year taping requirement begins on the date he again becomes an NFA Member or Associate and continues thereafter for one year. Only periods of time when he is registered and actively soliciting customers, on a full-time basis, will be counted.
If Connolly becomes a principal of an NFA Member, he shall cause all APs of that firm - and any other firm of which he is a princpal - to tape record, for one year, all conversations that occur between them and existing or potential customers; retain the tapes for one year from the date they are created; and make the tapes available to NFA. The one-year taping requirement applies to each and every firm of which Connolly becomes a principal and begins on the date he becomes a principal of each firm, respectively. Only periods of time when Connolly is a principal of that particular firm and that firm is actively solictiing customers will be counted. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
DECISION:
On August 3, 2011, Dholakia was permanently barred from NFA membership, associate membership and from acting as a principal of any NFA Member. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
DECISION:
On October 10, 2011, pursuant to a settlement offer submitted by RJ Ginsberg and Ginsberg, RJ Ginsberg was ordered to withdraw from NFA membership within 30 days and thereafter, be permanently barred from NFA membership, associate membership or acting as a principal of an NFA Member.
Ginsberg was ordered to withdraw from NFA associate membership and principal status within 30 days and not apply for NFA membership, associate memberhsip or principal status for eighteen months beginning on July 13, 2011, the date on which RJ Ginsberg ceased doing business. During the eighteen-month period, Ginsberg may not act in any capacity requiring registration nor act as a principal of an NFA Member.
If, after expiration of the eighteen-month period, Ginsberg applies for NFA membership, associate membership or seeks to become a principal of an NFA Member, then he was ordered to pay a $5,000 fine, due and payable at the same time he applies for NFA membership, associate membership or becomes a principal of an NFA Member. Any future application made by Ginsberg for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless his fine has been paid in full.
If, after expiration of the eighteen-month period, Ginsberg applies for NFA membership or associate membership or seeks to become a principal of an NFA Member, (a) he shall only act as the sole AP and principal of a sole-proprietor firm of which he is the owner or, alternatively, (b) he shall only act as an AP of an NFA Member, but not as a principal of that NFA Member or in any position or capacity that requires him to oversee or supervise the activities of APs.
If Ginsberg elects to operate as a sole proprietor he shall make and keep evidence - for one year - showing that all trades placed in customers' self-directed, non-discretionary trading accounts were authorized by the customers. Such evidence must include, at a minimum, a tape recorded conversation with the customer in which the customer verbally authorizes and confirms the trade(s) in question. Such tape recorded confirmations must be retained for one year from the date they are created and made available to NFA. The one-year taping requirement applies to each and every sole proprietorship which Ginsberg operates in the future and begins on the date that the sole proprietorship begins operations. Only periods of time when the sole proprietorship has active customer-directed, non-discretionary accounts will be counted. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
DECISION:
On August 3, 2011, pursuant to a settlement offer submitted by Jenkins, he was ordered to withdraw from NFA associate membership and principal status within 30 days and not apply for NFA membership, associate membership or principal status for three years from the date of his withdrawal. During the three-year period, Jenkins may not act in any capacity requiring registration or as a principal of an NFA Member.
If, after expiration of the three-year period, Jenkins applies for NFA membership, associate membership or seeks to become a principal of an NFA Member, he was ordered to pay a $10,000 fine.
In the event Jenkins becomes a principal of an NFA Member, he shall cause the Member - for one year - to make and keep evidence that all trades placed in customers' self-directed, non-discretionary trading accounts, were authorized by the customers. This evidence must include, at a minimum, a tape recorded conversation with the customer in which the customer verbally authorizes and confirms the trade(s) in question. The tape recorded confirmations must be retained for one year from the date they are created and be made available to NFA. The one-year taping requirement applies to each and every firm of which Jenkins becomes a principal and begins on the date he becomes a principal of each firm, respectively. Only periods of time when Jenkins is a principal of that particular firm, and the firm has active customer-directed, non-discretionary accounts, will be counted. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
DECISION:
On October 10, 2011, pursuant to a settlement offer submitted by RJ Ginsberg and Ginsberg, RJ Ginsberg was ordered to withdraw from NFA membership within 30 days and thereafter, be permanently barred from NFA membership, associate membership or acting as a principal of an NFA Member.
Ginsberg was ordered to withdraw from NFA associate membership and principal status within 30 days and not apply for NFA membership, associate memberhsip or principal status for eighteen months beginning on July 13, 2011, the date on which RJ Ginsberg ceased doing business. During the eighteen-month period, Ginsberg may not act in any capacity requiring registration nor act as a principal of an NFA Member.
If, after expiration of the eighteen-month period, Ginsberg applies for NFA membership, associate membership or seeks to become a principal of an NFA Member, then he was ordered to pay a $5,000 fine, due and payable at the same time he applies for NFA membership, associate membership or becomes a principal of an NFA Member. Any future application made by Ginsberg for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless his fine has been paid in full.
If, after expiration of the eighteen-month period, Ginsberg applies for NFA membership or associate membership or seeks to become a principal of an NFA Member, (a) he shall only act as the sole AP and principal of a sole-proprietor firm of which he is the owner or, alternatively, (b) he shall only act as an AP of an NFA Member, but not as a principal of that NFA Member or in any position or capacity that requires him to oversee or supervise the activities of APs.
If Ginsberg elects to operate as a sole proprietor he shall make and keep evidence - for one year - showing that all trades placed in customers' self-directed, non-discretionary trading accounts were authorized by the customers. Such evidence must include, at a minimum, a tape recorded conversation with the customer in which the customer verbally authorizes and confirms the trade(s) in question. Such tape recorded confirmations must be retained for one year from the date they are created and made available to NFA. The one-year taping requirement applies to each and every sole proprietorship which Ginsberg operates in the future and begins on the date that the sole proprietorship begins operations. Only periods of time when the sole proprietorship has active customer-directed, non-discretionary accounts will be counted. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On May 19, 2011, NFA issued a Complaint charging RJ Ginsberg, Connolly, Dholakia, Wechsler, Ginsberg and Jenkins with failing to uphold just and equitable principles of trade. The Complaint also charged RJ Ginsberg, Connolly, Dholakia and Wechsler with exercising discretion over customers' accounts without obtaining written authority to exercise such discretion. In addition, the Complaint charged RJ Ginsberg and Dholakia with failing to provide adequate risk disclosure. The Complaint further charged RJ Ginsberg with allowing an unregistered individual to act in a capacity requiring registration as an AP. Finally, the Complaint charged RJ Ginsberg, Ginsberg and Jenkins with failing to supervise the firm's APs and activities.
ANSWER:
On June 21, 2011, Wechsler filed an Answer to the Complaint in which she denied the material allegations contained therein. | | |
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| 0334662 | CONNOLLY, MARTIN LAWRENCE | ANSWER | | 0334662 | CONNOLLY, MARTIN LAWRENCE | COMPLAINT | | 0334662 | CONNOLLY, MARTIN LAWRENCE | DECISION | | 0079445 | DHOLAKIA, ALAKESH P | COMPLAINT | | 0079445 | DHOLAKIA, ALAKESH P | DECISION | | 0235486 | GINSBERG, RANDOLPH JACOB | COMPLAINT | | 0235486 | GINSBERG, RANDOLPH JACOB | DECISION | | 0098246 | JENKINS, JEFFREY BERNARD | COMPLAINT | | 0098246 | JENKINS, JEFFREY BERNARD | DECISION | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | COMPLAINT | | 0259174 | RANDOLPH J GINSBERG INTRODUCING BROKERAGE INC | DECISION | | 0196824 | WECHSLER, JEANNE RUTH | ANSWER | | 0196824 | WECHSLER, JEANNE RUTH | COMPLAINT |
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