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STATE OF
OFFICE OF SECURITIES
121 STATE HOUSE STATION
________________________________
)
IN THE MATTER OF: )
) CONSENT AGREEMENT
Bangor Securities, Inc. ) No. 06-035-CAG
Michael E. Ludwig
)
_______________________________ )
This Agreement is entered into by the
State of
WHEREAS,
the parties agree as follows:
1.
Pursuant to 32 M.R.S.A. § 10303(1),
a person may not act in
2.
Pursuant to 32 M.R.S.A. § 10303(3),
it is unlawful for an investment adviser licensed or required to be licensed under
the Act to employ or contract with an individual as a representative of the investment
adviser in Maine unless the individual is licensed;
3.
The Office has reviewed the licensing
records of Bangor Securities, Inc., and of Ludwig; Bangor Securities, Inc., has
been licensed as an investment adviser since at least June 26, 2002, and Ludwig
has been licensed as an investment adviser representative since November 18, 2005;
4.
It is the Office’s position that, prior
to becoming licensed as an investment adviser representative, Ludwig acted as
investment adviser representative in Maine without being licensed or exempt from
licensing;
5.
Bangor Securities, Inc., has represented
to the Office that the failure to obtain an investment adviser representative
license for Ludwig was inadvertent; and
6.
All parties desire an expeditious resolution
of this matter.
NOW, THEREFORE, without trial or adjudication of any issue of fact or law, and without
Bangor Securities, Inc., or Ludwig admitting or denying that their conduct violated
the Act, it is agreed that:
1. Bangor Securities, Inc., and Ludwig will comply
with all licensing and other legal requirements governing persons acting as investment
advisers and investment adviser representatives in the State of Maine at all times
from the date hereof;
2. In lieu of the Office seeking the imposition
of a penalty for the allegations contained herein, Bangor Securities, Inc., and
Ludwig will pay the sum of $1,500.00 to the Office upon their execution of this
Agreement; and
3. The Office will not take further action against
Bangor Securities, Inc., or Ludwig based solely upon Ludwig’s unlicensed status
during the period preceding November 18, 2005.
Bangor Securities, Inc.
By:
December 14, 2005 s/Eric Bossidy
Date
Eric G. Bossidy
Vice President and
Chief Compliance Officer
December 12, 2005 s/Michael
E. Ludwig
Date
Michael E. Ludwig
December 15, 2005 s/Michael
J. Colleran
Date
Michael J. Colleran
Securities Administrator
Reviewed by:
December 16, 2005 s/Bonnie
E. Russell
Date
Bonnie Russell
Assistant Securities Administrator
Submitted by:
December 15, 2005 s/Jacqueline
M. Drouin
Date
Jacqueline M. Drouin
Investigator/Examiner