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STATE
OF
SECURITIES
DIVISION
121
STATE HOUSE STATION
_______________________________
IN THE MATTER OF:
______________________________
This Agreement is entered into
between the State of
WHEREAS,
the parties agree as follows:
1. At all relevant times, it has been
unlawful in Maine for a person to act as a broker-dealer unless licensed or
exempt from licensing under the Revised Maine Securities Act, Title 32 Maine
Revised Statutes Annotated §10101 et seq.
2.
At all relevant times it has been
unlawful in Maine for a broker-dealer to employ or contract with a person as a
sales representative unless the sales representative is licensed or exempt from
licensing under the Revised Maine Securities Act, Title 32 §10301.
3. Christopher Street Financial has been
licensed as a broker-dealer with the Securities Division since
4. As a result of a complaint filed by a
Maine resident with the Securities Division, it came to the attention of the
Maine Securities Division that Christopher Street Financial has effected (10)
transactions for (1) customer using an unlicensed sales representative.
5. It is the Securities Division’s
position that Christopher Street Financial employed an unlicensed sales
representative to effect transactions in violation of 32 M.R.S.A. § 10301.
6. Christopher Street Financial has
represented to the Securities Division that the violations were inadvertent and
were caused by a compliance oversight. The Maine Securities Division has no
reason to doubt these representations.
7. Both parties desire an expeditious
resolution of this matter.
NOW
THEREFORE, without trial or adjudication of any issue of fact or law, and
without Christopher Street Financial admitting or denying that its conduct
violated the Revised Maine Securities Act, it is agreed that:
1. Christopher Street Financial will
comply with all licensing and other legal requirements governing persons acting
as securities broker-dealers in the State of Maine at all times from the date
hereof;
2. In lieu of the Securities Division
seeking the imposition of a penalty for the allegations contained herein,
Christopher Street Financial will pay the sum of $6,049.16 to Warren Doe of Vienna, Maine upon
Christopher Street Financial’s execution of this
Agreement; and
3. The Securities Division will not take
further action against Christopher Street Financial, based upon its employment
of unlicensed sales representatives during the period preceding and including
the date of execution of this Agreement, PROVIDED,
however, that this paragraph applies only to those transactions previously
disclosed to the Securities Division by Christopher Street Financial.
Date Christine
A. Bruenn
Securities
Administrator
Date Kermit Johns
President, GSP & Director