STATE OF MAINE
OFFICE OF SECURITIES
AUGUSTA, MAINE 04333-0121
IN THE MATTER OF:
The Huntington Investment Company ) CONSENT AGREEMENT
) No. 05-056-CAG
This Agreement is entered into between the State of Maine Office of Securities (“Office”) and The Huntington
Investment Company (“Huntington” or “the firm”), a broker-dealer with its principal
place of business in Columbus,
WHEREAS, the parties agree as follows:
all relevant times, it has been unlawful in Maine for a person to act as a broker-dealer
unless licensed or exempt from licensing pursuant to sections 10301 and 10302
of the Revised Maine Securities Act (“the Act”).
Huntington has not been licensed in Maine as a broker-dealer.
April 14, 2003, Huntington’s chief compliance officer
informed the Office that the firm had some Maine accounts. The Office explained how unlicensed activity
is generally resolved, and Huntington agreed to
seek licensure in Maine.
Huntington filed an application with the Office
of Securities for licensing as a broker-dealer on April 15, 2003.
May 22, 2003, the Office mailed Huntington a letter
requesting additional information in connection with the firm’s pending broker-dealer
application and a detailed accounting of all business that the firm had conducted
in Maine within
the previous six years.
Huntington did not respond to the Office’s May
22, 2003, letter and later filed a request to withdraw its application on March
Office did not grant the firm’s request for withdrawal and made further inquiries
of Huntington with regard to the firm’s securities
activity in Maine. In response to the Office’s inquiries, Huntington disclosed that it had effected at least eighty-nine
(89) transactions between June 10, 1998, and August 4, 2004, for the accounts
of nineteen (19) Maine
consumers while unlicensed.
is the Office of Securities’ position that Huntington
has acted as a broker-dealer in Maine
without being licensed or exempt from licensing.
Huntington has represented to the Office that
the firm makes every effort to comply with federal and state regulations.
10. Both parties desire an expeditious
resolution of this matter.
NOW, THEREFORE, without trial or adjudication of
any issue of fact or law, and without Huntington
admitting or denying that its conduct violated the Revised Maine Securities Act,
it is agreed that:
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
lieu of the Office of Securities seeking the imposition of a penalty for the allegations
contained herein, Huntington will pay the sum of $3,000 to the Office upon Huntington’s
execution of this Agreement; and
Office of Securities will not take further action against Huntington,
based upon its unlicensed status 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 Office by Huntington.
s/Robert J. Comfort, President
Robert J. Comfort, President
The Huntington Investment Company
s/Michael J. Colleran
Michael J. Colleran
s/Bonnie E. Russell
Bonnie E. Russell
Assistant Securities Administrator
s/Cathy J. Williams
Cathy J. Williams