Fordham Financial CRD

BrokerCheck Report

FORDHAM FINANCIAL MANAGEMENT, INC.

Report #75052-63374, data current as of Monday, January 26, 2015.

Section Title

Report Summary

Firm History

CRD# 20996

1

7

Firm Profile 2 - 6

Page(s)

Firm Operations 8 - 14

Disclosure Events 15

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FORDHAM FINANCIALMANAGEMENT, INC.

CRD# 20996

SEC# 8-38622

Main Office Location

17 BATTERY PLACE, SOUTHSUITE 643NEW YORK, NY 10004Regulated by FINRA New York Office

Mailing Address

17 BATTERY PLACE, SOUTHSUITE 643NEW YORK, NY 10004

Business Telephone Number

212-732-8500

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 7

Arbitration 1

Firm Profile

This firm is classified as a corporation.

This firm was formed in Colorado on 09/21/1987.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 4 types of businesses.

This firm is not affiliated with any financial orinvestment institutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 50 U.S. states and territories

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1©2015 FINRA. All rights reserved. Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.


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This firm is classified as a corporation.

This firm was formed in Colorado on 09/21/1987.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

FORDHAM FINANCIAL MANAGEMENT, INC.

SEC#

20996

8-38622

Main Office Location

Mailing Address

Business Telephone Number

Doing business as FORDHAM FINANCIAL MANAGEMENT, INC.

212-732-8500

Regulated by FINRA New York Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

FORDHAM HOLDING GROUP, INC.

SHAREHOLDER

75% or more

No

Domestic Entity

03/1996

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ADAMS, RICHARD JOSEPH

FINOP

Less than 5%

No

Individual

08/1999

Yes

1072936



Position


Position Start Date

BAQUET, EDWARD MANUEL

GENERAL PRINCIPLE, CROP/ROP/SROP, HEAD TRADER

Less than 5%

Individual

05/2009

4986983








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


BAQUET, WILLIAM

GENERAL PRINCIPAL, PRESIDENT, DIRECTOR, SECRETARY, TREASURER

Less than 5%

No

Individual

08/1999

Yes

1332676



Position



Position Start Date


CALAMUNCI, ROBERT JOSEPH SR

MSRB PRINCIPAL

Less than 5%

No

Individual

05/2013

No

1618899



GIORDANO, CHARLES FRANCIS

2124257







Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


MANAGING DIRECTOR, GENERAL PRINCIPAL

Less than 5%

No

Individual

07/1997

Yes

2124257


Position



Position Start Date


HENDERSON, PHYLLIS ANNE

CHIEF COMPLIANCE OFFICER, AML COMPLIANCE OFFICER

Less than 5%

No

Individual

05/2009

Yes

1343053








This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

BAQUET, WILLIAM

PRESIDENT, SECRETARY

FORDHAM HOLDINGS GROUP

75% or more

No

Individual

06/1997

Yes

1332676



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 1 SRO and 50 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 10/23/1987

Self-Regulatory Organization Status Date Effective

FINRA Approved 11/13/1987






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 01/29/1997

Alaska Approved 02/10/1997

Arizona Approved 01/29/1997

Arkansas Approved 02/05/1997

California Approved 05/30/1996

Colorado Approved 11/24/1987

Connecticut Approved 04/24/1996

Delaware Approved 05/16/1996

District of Columbia Approved 04/07/1996

Florida Approved 07/30/1996

Georgia Approved 03/13/1996

Hawaii Approved 10/06/1997

Idaho Approved 01/27/1997

Illinois Approved 06/05/1996

Indiana Approved 01/05/1998

Iowa Approved 01/16/1997

Kansas Approved 07/15/1996

Kentucky Approved 01/13/1997

Louisiana Approved 01/28/1997

Maine Approved 10/31/2007

Maryland Approved 02/07/1996

Massachusetts Approved 06/05/1996

Michigan Approved 02/26/1997

Minnesota Approved 06/05/1996

Mississippi Approved 03/05/1997

Missouri Approved 04/06/1988

Montana Approved 01/14/1997

Nebraska Approved 11/26/1997

Nevada Approved 01/09/1997

New Jersey Approved 09/10/1996

New Mexico Approved 02/05/1997

New York Approved 05/24/1996

North Carolina Approved 09/24/1996

U.S. States &Territories

Status Date Effective

North Dakota Approved 03/11/2002

Ohio Approved 02/03/1997

Oklahoma Approved 08/20/1996

Oregon Approved 02/05/1997

Pennsylvania Approved 06/14/1996

Puerto Rico Approved 08/07/2007

Rhode Island Approved 01/28/1997

South Carolina Approved 01/14/1997

South Dakota Approved 01/22/1997

Tennessee Approved 02/06/1997

Texas Approved 09/23/1997

Virgin Islands Approved 09/10/2007

Virginia Approved 07/17/1996

Washington Approved 01/17/1997

West Virginia Approved 01/14/1997

Wisconsin Approved 07/29/1997

Wyoming Approved 07/31/1997






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

This firm currently conducts 4 types of businesses.

Types of Business

Broker or dealer retailing corporate equity securities over-the-counter

Put and call broker or dealer or option writer

Trading securities for own account

Private placements of securities






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: COR CLEARING LLC

Business Address: 9300 UNDERWOOD AVENUESUITE 400OMAHA, NE 68114

CRD #: 117176

Effective Date: 11/20/2012

Description: FULLY DISCLOSED CLEARING AGREEMENT --






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Name: SILVERSKY, INC. (F/K/A USA.NET)

Business Address: 2 PENN PLAZA, SUITE 1990NEW YORK, NY 10121


Description: SILVERSKY,INC. (FORMERLY KNOWN AS USA.NET, OUR PREVIOUSPROVIDER) PROVIDES A COMPLETE MESSAGING SOLUTION WHICHENABLES THE FIRM TO EMPLOY COMPREHENSIVE SUPERVISORYPROCESSES TO REVIEW ELECTRONIC CORRESPONDENCE ANDELECTRONIC DATA STORAGE SERVICES UTILIZING NON-OPTICALELECTRONIC STORAGE MEDIA. (NAME CHANGED FROM SECCAS TOUSA.NET, INC.)

Name: COR CLEARING LLC

Business Address: 9300 UNDERWOOD AVENUESUITE 400OMAHA, NE 68114

CRD #: 117176


Description: FULLY DISCLOSED CLEARING AGREEMENT

Name: VACE PARTNERS, LTD.,

Business Address: 1899 VICTORY BLVDSTATEN ISLAND, NY 10314


Description: VACE PARTNERS, LTD., TAX ID#13-3900632, HAS INVESTED $400,000 INFORDHAM HOLDINGS GROUP, INC., THE OWNER OF FORDHAMFINANCIAL MANGEMENT, INC., BY PURCHASING 80,000 SERIES BPREFERRED (NO VOTING RIGHTS) SHARES OF FORDHAM HOLDINGSGROUP, INC., IN A PRIVATE TRANSACTION. 12©2015 FINRA. All rights reserved. Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.





Firm Operations

Industry Arrangements (continued)

PREFERRED (NO VOTING RIGHTS) SHARES OF FORDHAM HOLDINGSGROUP, INC., IN A PRIVATE TRANSACTION.

Name: 1060 RICHMOND ROAD, CORP,

Business Address: 1060 RICHMOND ROADSTATEN ISLAND, NY 10314


Description: 1060 RICHMOND ROAD, CORP., TAX ID #13-3072316, HAS INVESTED$50,000 IN FORDHAM HOLDINGS GROUP, INC., THE OWNER OFFORDHAM FINANCIAL MANAGEMENT, INC., BY PURCHASING 10,000SERIES B PREFERRED SHARES (NO VOTING RIGHTS OF FORDHAMHOLDINGS GROUP, INC. IN A PRIVATE TRANSACTION.

Name: JANGIZ DEMIRKAN

Business Address: 424 JEFFERSON AVENUESTATEN ISLAND, NY 10306


Description: SS#067-46-4777, HAS INVESTED $50,000 IN FORDHAM HOLDINGSGROUP, INC., THE OWNER OF FORDHAM FINANCIAL MANAGEMENT,INC., BY PURCHASING 10,000 SERIES B PREFERRED (NO VOTINGRIGHTS) SHARES OF FORDHAM HOLDINGS GROUP, INC. IN A PRIVATETRANSACTION.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is not, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 7 0

Arbitration N/A 1 N/A






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 7

Reporting Source: Regulator

Allegations: FINRA RULE 7450 - FORDHAM FINANCIAL MANAGEMENT, INC.IMPROPERLY REPORTED EXECUTION OR COMBINED ORDER/EXECUTIONREPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITH AREPORTING EXCEPTION OF "M." THE FIRM TRANSMITTED REPORTS TOOATS THAT CONTAINED INACCURATE CAPACITY CODES.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/01/2012

Docket/Case Number: 2010023689701

Principal Product Type: No Product

Other Product Type(s):

Allegations: FINRA RULE 7450 - FORDHAM FINANCIAL MANAGEMENT, INC.IMPROPERLY REPORTED EXECUTION OR COMBINED ORDER/EXECUTIONREPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITH AREPORTING EXCEPTION OF "M." THE FIRM TRANSMITTED REPORTS TOOATS THAT CONTAINED INACCURATE CAPACITY CODES.

Resolution Date: 06/01/2012

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000. FINE PAID INFULL ON SEPTEMBER 21, 2012.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: FINRA

Allegations: FINRA RULE 7450 -- THE FIRM IMPROPERLY REPORTED EXECUTION ORCOMBINED ORDER/EXECUTION REPORTS TO OATS WITH A REPORTINGEXCEPTION OF 'M', THEREFORE, THE FIRM TRANSMITTED REPORTS TOOATS THAT CONTAINED INACCURATE CAPACITY CODES.






http://disciplinaryactions.finra.org/CaseAuthentication.aspx?CaseNB=2010023689701


Initiated By: FINRA








Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THEFIRM WAS CENSURED AND FINED $10,000.00.



Disclosure 2 of 7

i


Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES17A-3, 17A-4 THEREUNDER, SEC REGULATION M, RULE 101, FINRA RULES2010, 3130(B), 5190(C), 5190(C)(1)(A), NASD RULES 2110, 2860(B)(16), 3010,3010(B), 3010(D), 3011(B), 3011(C), 3013(B), 3070(C), 3110(A): THE FIRMFAILED TO FILE AN SEC REGULATION M RESTRICTED PERIODNOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENTOFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERINGWAS A DISTRIBUTION WITHIN THE MEANING OF SEC REGULATION M,RULE 100 AND THEREFORE, IT WAS SUBJECT TO THE REQUIREMENTS OFTHE REGULATION AND OF FINRA RULE 5190(C). THE OFFERING PRICEWAS DETERMINED AFTER THE CLOSE OF BUSINESS ON APRIL 30, 2009.ACCORDINGLY, THE REGULATION M PERIOD FOR THE OFFERING BEGANON APRIL 24, 2009 AND THE FIRM SHOULD HAVE RESTRICTED ITSTRADING IN THE COMPANY AND THE SOLICITATION OF TRADES IN THATCOMPANY'S SECURITIES BEGINNING ON THAT DATE. THE FIRM DID NOT.AS A RESULT, WHEN THE OFFERING WAS CANCELED FOLLOWINGDISCOVERY BY THE FIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURETO FILE THE RESTRICTED PERIOD NOTIFICATION FORM, THE FIRMTHROUGH ITS AGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19CUSTOMER PURCHASES, AND A FIRM REGISTERED REPRESENTATIVEIMPROPERLY MADE TWO PURCHASE OF THE STOCK FOR HIS OWNACCOUNT. AS A RESULT, THE FIRM WILLFULLY VIOLATED SECREGULATION M, RULE 101, AND FINRA RULES 2010 AND 5190(C)(1)(A). THEFIRM FAILED TO CAPTURE THE TIMES OF ITS RECEIPTS OF CUSTOMERORDERS. AS A RESULT, THE FIRM WILLFULLY VIOLATED SECTION 17(A) OFTHE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4THEREUNDER, FINRA RULE 2010, AND NASD RULES 2110 AND 3110(A). ASIMPLEMENTED BY THE FIRM'S ANTI-MONEY LAUNDERING (AML)COMPLIANCE OFFICER, THE FIRM'S AML POLICIES, PROCEDURES ANDINTERNAL CONTROLS WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE BANK SECRECY ACT (BSA) AND ITSIMPLEMENTING REGULATIONS. THE FIRM, THROUGH ITS AMLCOMPLIANCE OFFICER, FAILED TO ADEQUATELY IMPLEMENT ITSCUSTOMER IDENTIFICATION PROGRAM (CIP) IN THAT IT FAILED TODOCUMENT THAT IT A) HAD OBTAINED CERTAIN REQUIRED PIECES OFINFORMATION TO VERIFY THE CUSTOMER'S IDENTITY IN FIVE OF 51ACCOUNTS SAMPLED BY FINRA'S EXAMINATION STAFF, B) HADPERFORMED ANY VERIFICATION OF THE CUSTOMER'S IDENTITY AT ALL IN16 OF 51 ACCOUNTS SAMPLED, AND C) HAD PERFORMED THE REQUIREDNON-DOCUMENTARY VERIFICATION FOR 28 ACCOUNTS. THE FIRM FAILEDTO ESTABLISH AND ENFORCE AN ADEQUATE AML COMPLIANCEPROGRAM AND FAILED TO PROVIDE FOR INDEPENDENT TESTING FORCOMPLIANCE WITH ITS AML OBLIGATIONS. THE FIRM FAILED TO REPORTCUSTOMER COMPLAINTS NO LATER THAN THE 15TH DAY FOLLOWING THEEND OF THE CALENDAR QUARTER IN WHICH THOSE COMPLAINTS WERERECEIVED. THE FIRM IMPROPERLY PERMITTED OPTIONS TRADING,FAILED TO RETAIN OPTION AGREEMENTS, AND FAILED TO OBTAINESSENTIAL INFORMATION ON THE CLIENT OPTION AGREEMENT INCUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH, MAINTAIN ANDENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH SEC REGULATION M, RULES100 THROUGH 105 AND FINRA RULE 5190. THE FIRM ALSO FAILED TOENFORCE WSPS TO SUPERVISE ITS REGISTERED REPRESENTATIVES.SPECIFICALLY, THE FIRM FAILED TO CONDUCT TRANSACTION REVIEWSAND FAILED TO ESTABLISH AND ENFORCE HEIGHTENED SUPERVISION.THE FIRM'S CHIEF EXECUTIVE OFFICER WAS REQUIRED TO SIGN, ONBEHALF OF THE FIRM, THE CHIEF EXECUTIVE OFFICER CERTIFICATIONSCERTIFYING THE FIRM'S WRITTEN COMPLIANCE POLICIES AND WSPS. THECHIEF EXECUTIVE OFFICER FAILED TO SIGN SUCH CERTIFICATIONS FORTHE YEARS 2008 AND 2009.








Initiated By: FINRA

DISCOVERY BY THE FIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURETO FILE THE RESTRICTED PERIOD NOTIFICATION FORM, THE FIRMTHROUGH ITS AGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19CUSTOMER PURCHASES, AND A FIRM REGISTERED REPRESENTATIVEIMPROPERLY MADE TWO PURCHASE OF THE STOCK FOR HIS OWNACCOUNT. AS A RESULT, THE FIRM WILLFULLY VIOLATED SECREGULATION M, RULE 101, AND FINRA RULES 2010 AND 5190(C)(1)(A). THEFIRM FAILED TO CAPTURE THE TIMES OF ITS RECEIPTS OF CUSTOMERORDERS. AS A RESULT, THE FIRM WILLFULLY VIOLATED SECTION 17(A) OFTHE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4THEREUNDER, FINRA RULE 2010, AND NASD RULES 2110 AND 3110(A). ASIMPLEMENTED BY THE FIRM'S ANTI-MONEY LAUNDERING (AML)COMPLIANCE OFFICER, THE FIRM'S AML POLICIES, PROCEDURES ANDINTERNAL CONTROLS WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE BANK SECRECY ACT (BSA) AND ITSIMPLEMENTING REGULATIONS. THE FIRM, THROUGH ITS AMLCOMPLIANCE OFFICER, FAILED TO ADEQUATELY IMPLEMENT ITSCUSTOMER IDENTIFICATION PROGRAM (CIP) IN THAT IT FAILED TODOCUMENT THAT IT A) HAD OBTAINED CERTAIN REQUIRED PIECES OFINFORMATION TO VERIFY THE CUSTOMER'S IDENTITY IN FIVE OF 51ACCOUNTS SAMPLED BY FINRA'S EXAMINATION STAFF, B) HADPERFORMED ANY VERIFICATION OF THE CUSTOMER'S IDENTITY AT ALL IN16 OF 51 ACCOUNTS SAMPLED, AND C) HAD PERFORMED THE REQUIREDNON-DOCUMENTARY VERIFICATION FOR 28 ACCOUNTS. THE FIRM FAILEDTO ESTABLISH AND ENFORCE AN ADEQUATE AML COMPLIANCEPROGRAM AND FAILED TO PROVIDE FOR INDEPENDENT TESTING FORCOMPLIANCE WITH ITS AML OBLIGATIONS. THE FIRM FAILED TO REPORTCUSTOMER COMPLAINTS NO LATER THAN THE 15TH DAY FOLLOWING THEEND OF THE CALENDAR QUARTER IN WHICH THOSE COMPLAINTS WERERECEIVED. THE FIRM IMPROPERLY PERMITTED OPTIONS TRADING,FAILED TO RETAIN OPTION AGREEMENTS, AND FAILED TO OBTAINESSENTIAL INFORMATION ON THE CLIENT OPTION AGREEMENT INCUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH, MAINTAIN ANDENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH SEC REGULATION M, RULES100 THROUGH 105 AND FINRA RULE 5190. THE FIRM ALSO FAILED TOENFORCE WSPS TO SUPERVISE ITS REGISTERED REPRESENTATIVES.SPECIFICALLY, THE FIRM FAILED TO CONDUCT TRANSACTION REVIEWSAND FAILED TO ESTABLISH AND ENFORCE HEIGHTENED SUPERVISION.THE FIRM'S CHIEF EXECUTIVE OFFICER WAS REQUIRED TO SIGN, ONBEHALF OF THE FIRM, THE CHIEF EXECUTIVE OFFICER CERTIFICATIONSCERTIFYING THE FIRM'S WRITTEN COMPLIANCE POLICIES AND WSPS. THECHIEF EXECUTIVE OFFICER FAILED TO SIGN SUCH CERTIFICATIONS FORTHE YEARS 2008 AND 2009.







Other


N/A



Principal Product Type: Other

Other Product Type(s): PRIVATE PLACEMENTS


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS THAT IT VIOLATED SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934, RULES 17A-3 AND 17A-4 THEREUNDER, SECREGULATION M, RULE 101, FINRA RULES 2010, 3130(B), AND 5190(C)(1)(A),AND NASD RULES 2110, 2860(B)(16), 3010(B), 3010(D), 3011(B), 3011(A),3011(C), 3013, 3110(A), AND 3070(C), THEREFORE THE FIRM IS CENSUREDAND FINED $50,000. FINRA IMPOSED A LOWER FINE IN THIS CASE AFTERIS CONSIDERED, AMONG OTHER THINGS, THE FIRM'S REVENUES ANDFINANCIAL RESOURCES.


No


Decision & Order of Offer of Settlement


Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES17A-3, 17A-4 THEREUNDER, SEC REGULATION M, RULE 101, FINRA RULES2010, 3130(B), 5190(C), 5190(C)(1)(A), NASD RULES 2110, 2860(B)(16), 3010,3010(B), 3010(D), 3011(B), 3011(C), 3013(B), 3070(C), 3110(A): THE FIRMFAILED TO FILE AN SEC REGULATION M RESTRICTED PERIODNOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENTOFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERINGWAS SUBJECT TO THE REQUIREMENTS OF THE REGULATION AND OFFINRA RULE 5190(C). THE OFFERING PRICE WAS DETERMINED AFTER THECLOSE OF BUSINESS ON APRIL 30, 2009. ACCORDINGLY, THEREGULATION M PERIOD FOR THE OFFERING BEGAN ON APRIL 24, 2009AND THE FIRM SHOULD HAVE RESTRICTED ITS TRADING IN THECOMPANY AND THE SOLICITATION OF TRADES IN THAT COMPANY'SSECURITIES BEGINNING ON THAT DATE. THE FIRM DID NOT. AS A RESULT,WHEN THE OFFERING WAS CANCELED FOLLOWING DISCOVERY BY THEFIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURE TO FILE THERESTRICTED PERIOD NOTIFICATION FORM, THE FIRM THROUGH ITSAGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19 CUSTOMERPURCHASES, AND A FIRM REGISTERED REPRESENTATIVE IMPROPERLYMADE TWO PURCHASE OF THE STOCK FOR HIS OWN ACCOUNT. AS ARESULT, THE FIRM VIOLATED SEC REGULATION M, RULE 101, AND FINRARULES 2010 AND 5190(C)(1)(A). THE FIRM FAILED TO CAPTURE THE TIMESOF ITS RECEIPTS OF CUSTOMER ORDERS. AS A RESULT, THE FIRMVIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934AND RULES 17A-3 AND 17A-4 THEREUNDER, FINRA RULE 2010, AND NASDRULES 2110 AND 3110(A). AS IMPLEMENTED BY THE FIRM'S ANTI-MONEYLAUNDERING (AML) COMPLIANCE OFFICER, THE FIRM'S AML POLICIES,PROCEDURES AND INTERNAL CONTROLS WERE NOT REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT(BSA) AND ITS IMPLEMENTING REGULATIONS. THE FIRM FAILED TOADEQUATELY IMPLEMENT ITS CUSTOMER IDENTIFICATION PROGRAM(CIP) IN THAT IT FAILED TO DOCUMENT THAT IT A) HAD OBTAINEDCERTAIN REQUIRED PIECES OF INFORMATION TO VERIFY THECUSTOMER'S IDENTITY IN FIVE OF 51 ACCOUNTS SAMPLED BY FINRA'SEXAMINATION STAFF, B) HAD PERFORMED ANY VERIFICATION OF THECUSTOMER'S IDENTITY AT ALL IN 16 OF 51 ACCOUNTS SAMPLED, AND C)HAD PERFORMED THE REQUIRED NON-DOCUMENTARY VERIFICATIONFOR 28 ACCOUNTS. THE FIRM FAILED TO ESTABLISH AND ENFORCE ANADEQUATE AML COMPLIANCE PROGRAM AND FAILED TO PROVIDE FORINDEPENDENT TESTING FOR COMPLIANCE WITH ITS AML OBLIGATIONS.THE FIRM FAILED TO REPORT CUSTOMER COMPLAINTS NO LATER THANTHE 15TH DAY FOLLOWING THE END OF THE CALENDAR QUARTER INWHICH THOSE COMPLAINTS WERE RECEIVED. THE FIRM IMPROPERLYPERMITTED OPTIONS TRADING, FAILED TO RETAIN OPTION AGREEMENTS,AND FAILED TO OBTAIN ESSENTIAL INFORMATION ON THE CLIENT OPTIONAGREEMENT IN CUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH,MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS)REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECREGULATION M, RULES 100 THROUGH 105 AND FINRA RULE 5190. THEFIRM ALSO FAILED TO ENFORCE WSPS TO SUPERVISE ITS REGISTEREDREPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO CONDUCTTRANSACTION REVIEWS AND FAILED TO ESTABLISH AND ENFORCEHEIGHTENED SUPERVISION. THE FIRM'S CHIEF EXECUTIVE OFFICER WASREQUIRED TO SIGN, ON BEHALF OF THE FIRM, THE CHIEF EXECUTIVEOFFICER CERTIFICATIONS CERTIFYING THE FIRM'S WRITTENCOMPLIANCE POLICIES AND WSPS. THE CHIEF EXECUTIVE OFFICERFAILED TO SIGN SUCH CERTIFICATIONS FOR THE YEARS 2008 AND 2009.








NOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENTOFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERINGWAS SUBJECT TO THE REQUIREMENTS OF THE REGULATION AND OFFINRA RULE 5190(C). THE OFFERING PRICE WAS DETERMINED AFTER THECLOSE OF BUSINESS ON APRIL 30, 2009. ACCORDINGLY, THEREGULATION M PERIOD FOR THE OFFERING BEGAN ON APRIL 24, 2009AND THE FIRM SHOULD HAVE RESTRICTED ITS TRADING IN THECOMPANY AND THE SOLICITATION OF TRADES IN THAT COMPANY'SSECURITIES BEGINNING ON THAT DATE. THE FIRM DID NOT. AS A RESULT,WHEN THE OFFERING WAS CANCELED FOLLOWING DISCOVERY BY THEFIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURE TO FILE THERESTRICTED PERIOD NOTIFICATION FORM, THE FIRM THROUGH ITSAGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19 CUSTOMERPURCHASES, AND A FIRM REGISTERED REPRESENTATIVE IMPROPERLYMADE TWO PURCHASE OF THE STOCK FOR HIS OWN ACCOUNT. AS ARESULT, THE FIRM VIOLATED SEC REGULATION M, RULE 101, AND FINRARULES 2010 AND 5190(C)(1)(A). THE FIRM FAILED TO CAPTURE THE TIMESOF ITS RECEIPTS OF CUSTOMER ORDERS. AS A RESULT, THE FIRMVIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934AND RULES 17A-3 AND 17A-4 THEREUNDER, FINRA RULE 2010, AND NASDRULES 2110 AND 3110(A). AS IMPLEMENTED BY THE FIRM'S ANTI-MONEYLAUNDERING (AML) COMPLIANCE OFFICER, THE FIRM'S AML POLICIES,PROCEDURES AND INTERNAL CONTROLS WERE NOT REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT(BSA) AND ITS IMPLEMENTING REGULATIONS. THE FIRM FAILED TOADEQUATELY IMPLEMENT ITS CUSTOMER IDENTIFICATION PROGRAM(CIP) IN THAT IT FAILED TO DOCUMENT THAT IT A) HAD OBTAINEDCERTAIN REQUIRED PIECES OF INFORMATION TO VERIFY THECUSTOMER'S IDENTITY IN FIVE OF 51 ACCOUNTS SAMPLED BY FINRA'SEXAMINATION STAFF, B) HAD PERFORMED ANY VERIFICATION OF THECUSTOMER'S IDENTITY AT ALL IN 16 OF 51 ACCOUNTS SAMPLED, AND C)HAD PERFORMED THE REQUIRED NON-DOCUMENTARY VERIFICATIONFOR 28 ACCOUNTS. THE FIRM FAILED TO ESTABLISH AND ENFORCE ANADEQUATE AML COMPLIANCE PROGRAM AND FAILED TO PROVIDE FORINDEPENDENT TESTING FOR COMPLIANCE WITH ITS AML OBLIGATIONS.THE FIRM FAILED TO REPORT CUSTOMER COMPLAINTS NO LATER THANTHE 15TH DAY FOLLOWING THE END OF THE CALENDAR QUARTER INWHICH THOSE COMPLAINTS WERE RECEIVED. THE FIRM IMPROPERLYPERMITTED OPTIONS TRADING, FAILED TO RETAIN OPTION AGREEMENTS,AND FAILED TO OBTAIN ESSENTIAL INFORMATION ON THE CLIENT OPTIONAGREEMENT IN CUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH,MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS)REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECREGULATION M, RULES 100 THROUGH 105 AND FINRA RULE 5190. THEFIRM ALSO FAILED TO ENFORCE WSPS TO SUPERVISE ITS REGISTEREDREPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO CONDUCTTRANSACTION REVIEWS AND FAILED TO ESTABLISH AND ENFORCEHEIGHTENED SUPERVISION. THE FIRM'S CHIEF EXECUTIVE OFFICER WASREQUIRED TO SIGN, ON BEHALF OF THE FIRM, THE CHIEF EXECUTIVEOFFICER CERTIFICATIONS CERTIFYING THE FIRM'S WRITTENCOMPLIANCE POLICIES AND WSPS. THE CHIEF EXECUTIVE OFFICERFAILED TO SIGN SUCH CERTIFICATIONS FOR THE YEARS 2008 AND 2009.






Initiated By: FINRA






Other Product Type(s): PRIVATE PLACEMENT

REPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO CONDUCTTRANSACTION REVIEWS AND FAILED TO ESTABLISH AND ENFORCEHEIGHTENED SUPERVISION. THE FIRM'S CHIEF EXECUTIVE OFFICER WASREQUIRED TO SIGN, ON BEHALF OF THE FIRM, THE CHIEF EXECUTIVEOFFICER CERTIFICATIONS CERTIFYING THE FIRM'S WRITTENCOMPLIANCE POLICIES AND WSPS. THE CHIEF EXECUTIVE OFFICERFAILED TO SIGN SUCH CERTIFICATIONS FOR THE YEARS 2008 AND 2009.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE DESCRIBED SANTCTIONS AND TO THE ENTRY OFFINDINGS THAT IT VIOLATED SECTION 17(A) OF THE SEA OF 1934, RULES17A-4 THEREUNDER, SEC REGULATION M, RULE 101, FINRA RULES 2010,3130(B), AND 5190(C)(1)(A), AND NASD RULES 2110, 2860(B)(16), 3010(B),3010(D), 3011(B), 3011(A), AND 3070(C). THE FIRM WAS CENSURED ANDFINED $50,000.


Decision & Order of Offer of Settlement

Disclosure 3 of 7

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Initiated By: NASD

Allegations: NASD RULES 2110, 3070 - FORDHAM FINANCIAL MANAGEMENT, INC.,ACTING THROUGH AN INDIVIDUAL, FAILED TO REPORT STATISTICAL ANDSUMMARY INFORMATION REGARDING CUSTOMER COMPLAINTS ASREQUIRED BY NASD RULE 3070(C).








Initiated By: NASD




Docket/Case Number: E102005014702




Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $15,000, JOINTLY ANDSEVERALLY.


No




Initiated By: NASD


Docket/Case Number: E102005014702


Allegations: WITHOUT ADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIALMANAGEMENT AND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVEFAILED TO REPORT (6) EMAIL AND FAX STATISTICAL CUSTOMERCOMPLAINTS ON 3070 FILE






http://disciplinaryactions.finra.org/CaseAuthentication.aspx?CaseNB=E102005014702




Other


LETTER OF ACCEPTANCE WAIVER AND CONSENT "AWC" WITHOUTADMIOTTING OR DENYING ALLEGATIONS FRODHAM FINANCIALMANAGEMENT AND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVEFAILED TO REPORT 6 FAXES AND EMAIL CORRESPONDENCE. FOUR (4)FOR THE 3RD QTR 2004, AND ONE (1) IN THE 4TH QTR 2004, AND 1 IN THE1SR QTR 2005. ON THE FIRM 3070 CUSTOMER COMPLAINT FILE.


Other Product Type(s): STATISTICAL INFORMATION COMPLAINTS


Resolution:


Sanction Details: FINED AND CENSURED JOINTLY HARVEY LATZEN AND FORDHAMFINANCIAL MANAGEMENT $15,000.00 OF WHICH TOTAL WAS PAID BYFORDHAM FINANCIAL MANAGEMENT.

Firm Statement WITHOUT ADMITTING OR DENYING A LETTER OF ACCEPTANCE WAIVERAND CONSENT HAS NOW BEEN ACCEPTED BY NASD (NAC REVIEWCOMMITTEE).



Disclosure 4 of 7

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Initiated By: NASD



Docket/Case Number: C10050007



Allegations: NASD CONDUCT RULES 2110 AND 3070 - FORDHAM FINANCIALMANAGEMENT, INC., ACTING THROUGH HIS AN INDIVIDUAL, FAILED TOREPORT STATISTICAL AND SUMMARY INFORMATION REGARDINGCUSTOMER COMPLAINTS, AS REQUIRED BY NASD CONDUCT RULE3070(C).











Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRYOF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $8,000,JOINTLY AND SEVERALLY.


No




Initiated By: NASD


Other


LETTER OF ACCEPTANCE WAIVER AND CONSENT "AWC" WITHOUTADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIAL ANDHARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE FAILED TO REPORTSTATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THE ALLEGEDPARTICULAR COMPLAINTS WERE CARRIED IN THE CORRESPONDENCEFILE.




Other Product Type(s): STATISTICAL INFORMATION CUSTOMER COMPLAINTS FILINGS.

Allegations: WITHOUT ADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIALAND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE FAILED TOREPORT STATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THESEPARTICULAR COMPLAINTS WERE INSTEAD CARRIED ASCORRESPONDENCE IN CORRESPONDENCE FILE.









HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE FAILED TO REPORTSTATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THE ALLEGEDPARTICULAR COMPLAINTS WERE CARRIED IN THE CORRESPONDENCEFILE.


Resolution:


Sanction Details: FINED JOINTLY AND CENSURED HARVEY LATZEN AND FORDHAMFINANCIAL $8,000.00TOTAL PAID BY FORDHAM FINANCIAL MANAGEMENT.

Firm Statement WITHOUT ADMITTING OR DENYING A LETTER OF ACCEPTANCE WAIVERAND CONSENT HAS NOW BEEN ACCEPTED BY NASD (NAC)REVIEWCOMMITTEE.



Disclosure 5 of 7

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Initiated By: UTAH DIVISION OF SECURITIES


Revocation


FINE


Docket/Case Number: SD-02-0063



Allegations: EMPLOYING AN UNLICENSED AGENT; FAILURE TO SUPERVISE; FAILURETO MAINTAIN AND PROVIDE BOOKS AND RECORDS; DISHONEST ANDUNETHICAL BUSINESS PRACTICES BY NOT PROPERLY MAINTAINING ANDREPORTING CUSTOMER COMPLAINTS AND CORRESPONDENCE.



Resolution:

Sanctions Ordered: Monetary/Fine $15,000.00

Stipulation and Consent








Sanction Details: FINE OF $15,000.00 TO BE PAID AS FOLLOWS: $3,000 UPON EXECUTIONOF THE STIPULATION AND CONSENT ORDER; $1,000 EVERY 30 DAYS FORTEN MONTHS THEREFROM; AND THE FINAL $2,000 30 DAYS THEREFROM.

Regulator Statement ON JANUARY 22, 2001, JOHN ALEJOS, AN EMPLOYEE OF FORDHAM,SOLICITED A UTAH RESIDENT, WHO IS AN INVESTIGATOR WITH THE UTAHDIVISION OF SECURITIES, TO INVEST IN FOUNDRY NETWORKS WHILE HEDID NOT HAVE A SECURITIES LICENSE IN UTAH. ANOTHER AGENT OF THEFIRM, JOSEPH SCALI, SPOKE TO THE UTAH RESIDENT AND MISSTATEDMATERIAL FACTS. FROM DECEMBER 11-12, 2001, THE DIVISIONCONDUCTED AN AUDIT OF FORDHAM. DURING THE COURSE OF THEAUDIT, THE DIVISION FOUND THAT FORDHAMS BOOKS AND RECORDSWERE IMPROPERLY MAINTAINED. FOR MORE INFORMATION, PLEASEVISIT THE DIVISION'S WEB SITE AT:HTTP://WWW.SECURITIES.STATE.UT.US/ACTIONSEVENTS.ASP?DOCKET+NUMBER=SD%2D02%2D0063



Initiated By: STATE OF UTAH DIVISION OF SECURITIES


Other


WITHOUT ADMITTING OR DENYING INVESTIGATIVE CONCLUSIONS,CONSENTED TO PAY A FINE OF $15,000.00


Docket/Case Number: SD-02-0063

Principal Product Type: Equity - OTC


Allegations: FAILURE TO SUPERVISE



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE SUBSTANCE OF INVESTIGATIVECONCLUSION,CONSENTED TO AN ORDER REQUIRING THAT FORDHAMPAY A FINE OF $15,000.00


Stipulation and Consent







Sanction Details:CONCLUSION,CONSENTED TO AN ORDER REQUIRING THAT FORDHAMPAY A FINE OF $15,000.00

Firm Statement NEWLY REGISTERED INDIVIDUAL CALLED STATE. WAS NOT LICENSED INSTATE. SPOKE TO STATE REGULATOR. REPS LICENSE WAS TWO WEEKSOLD. REP WAS REPRIMANDED BY FIRM AND PUT ON NOTICE.COMPLIANCE DEPT REVIEWED FIRM POLICY AND REGULATIONS ABOUTBEING LICENSED IN STATE PRIOR TO CALLING WITH REP. FIRM SPOKE TOREGULATOR AND REPLIED IN WRITING. FORDHAM FINANCIAL NEITHERADMITS NOR DENIES THE SUBSTANCE OF THE DIVISIONS(UTAH'S)INVESTIGATIVE CONCLUSIONS, BUT CONSENTED TO THE DIVISIONSENTERING AND ORDER REQUIRING FORDHAM PAY A FINE OF $15,000.00

Disclosure 6 of 7

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.







Allegations: 06-01-00, NASD RULES 4632(A),6130(B),6420(A)(1), AND 6420(C)(2) -RESPONDENT MEMBER FAILED TO ACCEPT OR DECLINE NASDAQ ANDNON-NASDAQ TRANSACTIONS WITHIN 20 MINUTES;FAILED TO SUBMITWITHIN 90 SECONDS AFTER EXECUTION LAST SALE REPORTS OFNASDAQ NMS TRANSACTIONS AND CQS SECURITIES AND FAILED TODESIGNATE TRADES AS LATE WITH THE APPROPRIATE .SLD MODIFIERAND FOR ONE CQS TRANSACTION, THE TRANSACTION REPORTCONTAINED THE INCORRECT VOLUME; AND FAILED TO ACCEPT ORDECLINE TRANSACTIONS WITHIN 20 MINUTES OF EXECUTION.



Resolution:











Sanction Details: FINED $3,000


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Civil and Administrative Penalt(ies) /Fine(s)






Allegations: THE ALLEGATION WAS MEMBER FAILED TO ACCEPT OR DECLINE NASDAQAND NON-NASDAQ TRANSACTION WITHIN TWENTY MINUTES, FAILED TOSUBMIT WITHIN NINETY SECONDS AFTER EXECUTION REPORTS OFNASDAQ NMS TRANSACTIONS.



Resolution:


Sanction Details: FINED $3,000.00

Firm Statement FORDHAM FINANCIAL MANAGEMENT, INC. HAS ACCEPTED ANDCONSENTED WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.WHEN THESE ALLEGATIONS WERE BROUGHT TO THE FIRMS ATTENTIONTHE FIRM'S OBLIGATION WAS TO REVIEW THESE ALLEGATIONS WITH THEFIRM'S TRADING PERSONNEL, UNFORTUNATELY THE TRADINGINDIVIDUALS WERE NO LONGER WITH THE FIRM. CURRENTLY ALLTRADING EMPLOYEES ARE REQUIRED TO REVIEW MARKETMAKING/TRADING PROCEDURES AND TO INITIAL A COPY TO INSUREFAMILIARITY.



Disclosure 7 of 7

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Initiated By: THE OFFICE OF THE NORTH DAKOTA SECURITIES COMMISSIONER.


Denial



Docket/Case Number:



Allegations: THE SUBJECT FIRM ENGAGED IN BROKER/DEALER ACTIVITIES IN THESTATE OF NORTH DAKOTA WITHOUT REGISTRATION IN NORTH DAKOTA.THE SUBJECT FIRM PROVIDED FALSE INFORMATION TO THECOMMISSIONER WHEN THEY DENIED THAT THEY OFFERED FOR SALEAND/OR SOLD SECURITIES IN NORTH DAKOTA. THE SUBJECT FIRM WASNOT OF A GOOD BUSINESS REPUTATION BECAUSE OF THE DISCIPLINARYHISTORY OF ITS PRESENT.



Resolution:


Sanction Details: THE PENDING BROKER/DEALER APPLICATION OF THE SUBJECT FIRM WASDENIED.

Regulator Statement THE SUBJECT FIRM ENGAGED IN BROKER/DEALER ACTIVITIES IN THESTATE OF NORTH DAKOTA WITHOUT REGISTRATION IN NORTH DAKOTA.THE SUBJECT FIRM PROVIDED FALSE INFORMATION TO THECOMMISSIONER WHEN THEY DENIED THAT THEY OFFERED FOR SALEAND/OR SOLD SECURITIES IN NORTH DAKOTA. THE SUBJECT FIRM WASNOT OF A GOOD BUSINESS REPUTATION BECAUSE OF THE DISCIPLINARYHISTORY OF ITS PRESENT.

Sanctions Ordered: Revocation/Expulsion/Denial

Order


Allegations: THE STATE OF NORTH DAKOTA ALLEGED THAT FORDHAM FINANCIAL HADSOLD SECURITIES TO A SINGLE CLIENT WITHIN THE STATE OF NORTHDAKOTA WITHOUT REGISTRATION IN THE STATE. FORDHAM DENIED THEALLEGATIONS AND THE STATE FURTHER ALLEGED THAT FORDHAMPROVIDED FALSE INFORMATION IN CONNECTION WITH THIS DENIAL.








Initiated By: THE STATE OF NORTH DAKOTA


Revocation



Docket/Case Number:



Allegations: THE STATE OF NORTH DAKOTA ALLEGED THAT FORDHAM FINANCIAL HADSOLD SECURITIES TO A SINGLE CLIENT WITHIN THE STATE OF NORTHDAKOTA WITHOUT REGISTRATION IN THE STATE. FORDHAM DENIED THEALLEGATIONS AND THE STATE FURTHER ALLEGED THAT FORDHAMPROVIDED FALSE INFORMATION IN CONNECTION WITH THIS DENIAL.


Resolution:

Other Sanctions Ordered: APPLICATION FOR LICENSING IN STATE WAS DENIED.

Sanction Details: LICENSING WAS DENIED.

Firm Statement FORDHAM APPLIED FOR LICENSING IN THE STATE OF NORTH DAKOTA. INRESPONSE TO THIS APPLICATION, THE STATE CONTACTED FORDHAM'SCLEARING FIRM TO INQUIRE WHETHER ANY SALES HAD BEENCONDUCTED IN NORTH DAKOTA. UNBEKNOWNST TO FORDHAM, AFORDHAM CLIENT WHO HAD PREVIOUSLY RESIDED IN A NEIGHBORINGSTATE IN WHICH FORDHAM WAS REGISTERED HAD CHANGED HISMAILING ADDRESS TO NORTH DAKOTA. UNAWARE OF THIS, FORDHAMSOLD SECURITIES TO THIS CUSTOMER IN NORTH DAKOTA. THE CLIENTAND BROKER CONFIRMED THESE FACTS TO NORTH DAKOTAREGULATORS IN WRITING. DESPITE THIS, AND DESPITE EXTENSIVEEFFORTS TO RESOLVE THIS MATTER BY FORDHAM, NORTH DAKOTAPROCEEDED TO ENTER AN ORDER ON DEFAULT AGAINST FORDHAM,DENYING LICENSING. FORDHAM REAPPLIED FOR LICENSE AND WASGRANTED IN THE STATE 3/11/02.

Sanctions Ordered: Revocation/Expulsion/Denial

Order







Arbitration Award - Award/Judgment

Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 1


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

11/16/2000

00-05020

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS;ACCOUNT RELATED-NEGLIGENCE

UNKNOWN TYPE OF SECURITIES

$73,205.14

AWARD AGAINST PARTY

08/05/2002

$10,000.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.





http://finraawardsonline.finra.org/Search.aspx?CaseNum=00-05020


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