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BrokerCheck Report

FORDHAM FINANCIAL MANAGEMENT, INC.


CRD# 20996
Report #75052-63374, data current as of Monday, January 26, 2015.

Section Title

Page(s)

Report Summary

Firm Profile

2-6

Firm History

Firm Operations

8 - 14

Disclosure Events

15

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For more information about
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User Guidance

FORDHAM FINANCIAL
MANAGEMENT, INC.

Report Summary for this Firm

CRD# 20996

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

SEC# 8-38622

Firm Profile

Main Office Location

This firm is classified as a corporation.

17 BATTERY PLACE, SOUTH


SUITE 643
NEW YORK, NY 10004
Regulated by FINRA New York Office

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

Mailing Address
17 BATTERY PLACE, SOUTH
SUITE 643
NEW YORK, NY 10004

Information relating to the brokerage firm's history


such as other business names and successions
(e.g., mergers, acquisitions) can be found in the
detailed report.

Business Telephone Number

Firm Operations

212-732-8500

This firm is registered with:

Its fiscal year ends in December.

Firm History

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

Disclosure Events
Brokerage firms are required to disclose certain
criminal matters, regulatory actions, civil judicial
proceedings and financial matters in which the firm or
one of its control affiliates has been involved.
Are there events disclosed about this firm?

Yes

The following types of disclosures have been


reported:
Type
Count
Regulatory Event

Arbitration

Is this brokerage firm currently suspended with any


regulator? No
This firm conducts 4 types of businesses.
This firm is not affiliated with any financial or
investment institutions.
This firm has referral or financial arrangements with
other brokers or dealers.

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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User Guidance

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 Names and Locations


This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailing
addresses, telephone number, and any alternate name by which the firm conducts business and where such name is
used.
FORDHAM FINANCIAL MANAGEMENT, INC.
Doing business as FORDHAM FINANCIAL MANAGEMENT, INC.
CRD# 20996
SEC#

8-38622

Main Office Location


17 BATTERY PLACE, SOUTH
SUITE 643
NEW YORK, NY 10004
Regulated by FINRA New York Office
Mailing Address
17 BATTERY PLACE, SOUTH
SUITE 643
NEW YORK, NY 10004
Business Telephone Number
212-732-8500

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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User Guidance

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

Direct Owners and Executive Officers


Legal Name & CRD# (if any):

FORDHAM HOLDING GROUP, INC.

Is this a domestic or foreign


entity or an individual?

Domestic Entity

Position

SHAREHOLDER

Position Start Date

03/1996

Percentage of Ownership

75% or more

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

ADAMS, RICHARD JOSEPH


1072936

Is this a domestic or foreign


entity or an individual?

Individual

Position

FINOP

Position Start Date

08/1999

Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

BAQUET, EDWARD MANUEL


4986983

Is this a domestic or foreign


entity or an individual?

Individual

Position

GENERAL PRINCIPLE, CROP/ROP/SROP, HEAD TRADER

Position Start Date

05/2009

Percentage of Ownership
2015 FINRA. All rights reserved.

Less than 5%
Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

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User Guidance

Firm Profile
Direct Owners and Executive Officers (continued)
Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

BAQUET, WILLIAM
1332676

Is this a domestic or foreign


entity or an individual?

Individual

Position

GENERAL PRINCIPAL, PRESIDENT, DIRECTOR, SECRETARY, TREASURER

Position Start Date

08/1999

Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

CALAMUNCI, ROBERT JOSEPH SR


1618899

Is this a domestic or foreign


entity or an individual?

Individual

Position

MSRB PRINCIPAL

Position Start Date

05/2013

Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

No

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

GIORDANO, CHARLES FRANCIS

2015 FINRA. All rights reserved.

Report#2124257
75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

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User Guidance

Firm Profile
Direct Owners and Executive Officers (continued)
2124257
Is this a domestic or foreign
entity or an individual?

Individual

Position

MANAGING DIRECTOR, GENERAL PRINCIPAL

Position Start Date

07/1997

Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

Legal Name & CRD# (if any):

HENDERSON, PHYLLIS ANNE


1343053

Is this a domestic or foreign


entity or an individual?

Individual

Position

CHIEF COMPLIANCE OFFICER, AML COMPLIANCE OFFICER

Position Start Date

05/2009

Percentage of Ownership

Less than 5%

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

www.finra.org/brokercheck

User Guidance

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

Indirect Owners
Legal Name & CRD# (if any):

BAQUET, WILLIAM
1332676

Is this a domestic or foreign


entity or an individual?

Individual

Company through which


indirect ownership is
established

FORDHAM HOLDINGS GROUP

Relationship to Direct Owner

PRESIDENT, SECRETARY

Relationship Established

06/1997

Percentage of Ownership

75% or more

Does this owner direct the


management or policies of
the firm?

Yes

Is this a public reporting


company?

No

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

www.finra.org/brokercheck

User Guidance

Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.

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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User Guidance

Firm Operations
Registrations
This section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatory
organizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered and
licensed, 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.
Federal Regulator

Status

Date Effective

SEC

Approved

10/23/1987

SEC Registration Questions


This firm is registered with the SEC as:
A broker-dealer:

Yes

A broker-dealer and government securities broker or dealer:


A government securities broker or dealer only:

No

No

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

No

Self-Regulatory Organization

Status

Date Effective

FINRA

Approved

11/13/1987

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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User Guidance

Firm Operations
Registrations (continued)
U.S. States &
Territories

Status

Date Effective

U.S. States &


Territories

Status

Date Effective

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
New Mexico
New York
North Carolina

Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved

01/29/1997
02/10/1997
01/29/1997
02/05/1997
05/30/1996
11/24/1987
04/24/1996
05/16/1996
04/07/1996
07/30/1996
03/13/1996
10/06/1997
01/27/1997
06/05/1996
01/05/1998
01/16/1997
07/15/1996
01/13/1997
01/28/1997
10/31/2007
02/07/1996
06/05/1996
02/26/1997
06/05/1996
03/05/1997
04/06/1988
01/14/1997
11/26/1997
01/09/1997
09/10/1996
02/05/1997
05/24/1996
09/24/1996

North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved

03/11/2002
02/03/1997
08/20/1996
02/05/1997
06/14/1996
08/07/2007
01/28/1997
01/14/1997
01/22/1997
02/06/1997
09/23/1997
09/10/2007
07/17/1996
01/17/1997
01/14/1997
07/29/1997
07/31/1997

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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User Guidance

Firm Operations
Types of Business
This section provides the types of business, including non-securities business, the brokerage firm is engaged in or
expects 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

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

10

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User Guidance

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

CRD #:

117176

Business Address:

9300 UNDERWOOD AVENUE


SUITE 400
OMAHA, NE 68114

Effective Date:

11/20/2012

Description:

FULLY DISCLOSED CLEARING AGREEMENT --

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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User Guidance

Firm Operations
Industry Arrangements

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


Name:

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

Business Address:

2 PENN PLAZA, SUITE 1990


NEW YORK, NY 10121

Effective Date:

07/15/2011

Description:

SILVERSKY,INC. (FORMERLY KNOWN AS USA.NET, OUR PREVIOUS


PROVIDER) PROVIDES A COMPLETE MESSAGING SOLUTION WHICH
ENABLES THE FIRM TO EMPLOY COMPREHENSIVE SUPERVISORY
PROCESSES TO REVIEW ELECTRONIC CORRESPONDENCE AND
ELECTRONIC DATA STORAGE SERVICES UTILIZING NON-OPTICAL
ELECTRONIC STORAGE MEDIA. (NAME CHANGED FROM SECCAS TO
USA.NET, INC.)

Name:

COR CLEARING LLC

CRD #:

117176

Business Address:

9300 UNDERWOOD AVENUE


SUITE 400
OMAHA, NE 68114

Effective Date:

11/20/2012

Description:

FULLY DISCLOSED CLEARING AGREEMENT

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.
Control Persons/Financing
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.
Name:

VACE PARTNERS, LTD.,

Business Address:

1899 VICTORY BLVD


STATEN ISLAND, NY 10314

Effective Date:

07/24/1996

Description:

2015 FINRA. All rights reserved.

VACE PARTNERS, LTD., TAX ID#13-3900632, HAS INVESTED $400,000 IN


FORDHAM HOLDINGS GROUP, INC., THE OWNER OF FORDHAM
FINANCIAL MANGEMENT, INC., BY PURCHASING 80,000 SERIES B
PREFERRED (NO VOTING RIGHTS) SHARES OF FORDHAM HOLDINGS
Report#GROUP,
75052-63374
about
FINANCIAL
MANAGEMENT, INC. Data current as of Monday, January 26, 2015.
INC.,
INFORDHAM
A PRIVATE
TRANSACTION.

12

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User Guidance

Firm Operations
Industry Arrangements (continued)
PREFERRED (NO VOTING RIGHTS) SHARES OF FORDHAM HOLDINGS
GROUP, INC., IN A PRIVATE TRANSACTION.
Name:

1060 RICHMOND ROAD, CORP,

Business Address:

1060 RICHMOND ROAD


STATEN ISLAND, NY 10314

Effective Date:

09/26/1996

Description:

1060 RICHMOND ROAD, CORP., TAX ID #13-3072316, HAS INVESTED


$50,000 IN FORDHAM HOLDINGS GROUP, INC., THE OWNER OF
FORDHAM FINANCIAL MANAGEMENT, INC., BY PURCHASING 10,000
SERIES B PREFERRED SHARES (NO VOTING RIGHTS OF FORDHAM
HOLDINGS GROUP, INC. IN A PRIVATE TRANSACTION.

Name:

JANGIZ DEMIRKAN

Business Address:

424 JEFFERSON AVENUE


STATEN ISLAND, NY 10306

Effective Date:

08/17/1996

Description:

SS#067-46-4777, HAS INVESTED $50,000 IN FORDHAM HOLDINGS


GROUP, INC., THE OWNER OF FORDHAM FINANCIAL MANAGEMENT,
INC., BY PURCHASING 10,000 SERIES B PREFERRED (NO VOTING
RIGHTS) SHARES OF FORDHAM HOLDINGS GROUP, INC. IN A PRIVATE
TRANSACTION.

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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User Guidance

Firm Operations
Organization Affiliates
This section provides information on control relationships the firm has with other firms in the securities, investment
advisory, or banking business.

This firm is not, directly or indirectly:


in control of
controlled by
or under common control with
the following partnerships, corporations, or other organizations engaged in the securities or investment
advisory 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

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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User Guidance

Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or
civil 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 or
one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this
report.
Pending
Final
On Appeal
Regulatory Event
Arbitration

2015 FINRA. All rights reserved.

N/A

N/A

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

15

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User Guidance

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 includes
summary information regarding FINRA arbitration awards in cases where the brokerage firm was
named 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 firm
and a regulator report information for the same event, both versions of the event will appear in the
BrokerCheck report. The different versions will be separated by a solid line with the reporting source
labeled.
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 party
charged 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 for
business or other reasons.
A "resolved" matter usually involves no payment to the customer and no finding of
wrongdoing on the part of the individual broker. Such matters generally involve customer
disputes.
5. You may wish to contact the brokerage firm to obtain further information regarding any of the
disclosure 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 state
securities 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 or
suspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federal
contractor.
Disclosure 1 of 7
Reporting Source:

Regulator

Current Status:

Final

Allegations:

2015 FINRA. All rights reserved.

FINRA RULE 7450 - FORDHAM FINANCIAL MANAGEMENT, INC.


IMPROPERLY REPORTED EXECUTION OR COMBINED ORDER/EXECUTION

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

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User Guidance

Allegations:

FINRA RULE 7450 - FORDHAM FINANCIAL MANAGEMENT, INC.


IMPROPERLY REPORTED EXECUTION OR COMBINED ORDER/EXECUTION
REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITH A
REPORTING EXCEPTION OF "M." THE FIRM TRANSMITTED REPORTS TO
OATS THAT CONTAINED INACCURATE CAPACITY CODES.

Initiated By:

FINRA

Date Initiated:

06/01/2012

Docket/Case Number:

2010023689701

Principal Product Type:

No Product

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

06/01/2012

Does the order constitute a


final order based on
violations of any laws or
regulations that prohibit
fraudulent, manipulative, or
deceptive conduct?
Sanctions Ordered:

No

Censure
Monetary/Fine $10,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED


TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS CENSURED AND FINED $10,000. FINE PAID IN
FULL ON SEPTEMBER 21, 2012.

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

FINRA RULE 7450 -- THE FIRM IMPROPERLY REPORTED EXECUTION OR


COMBINED ORDER/EXECUTION REPORTS TO OATS WITH A REPORTING
EXCEPTION OF 'M', THEREFORE, THE FIRM TRANSMITTED REPORTS TO
OATS THAT CONTAINED INACCURATE CAPACITY CODES.

Initiated
By:All rights reserved.
2015
FINRA.

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

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User Guidance

Initiated By:

FINRA

Date Initiated:

06/01/2012

Docket/Case Number:

2010023689701

Principal Product Type:

No Product

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

06/01/2012

Sanctions Ordered:

Censure
Monetary/Fine $10,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED


TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE
FIRM WAS CENSURED AND FINED $10,000.00.

i
Disclosure 2 of 7
Reporting Source:

Regulator

Current Status:

Final

Allegations:

2015 FINRA. All rights reserved.

SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES


17A-3, 17A-4 THEREUNDER, SEC REGULATION M, RULE 101, FINRA RULES
2010, 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 FIRM
FAILED TO FILE AN SEC REGULATION M RESTRICTED PERIOD
NOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENT
OFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERING
WAS A DISTRIBUTION WITHIN THE MEANING OF SEC REGULATION M,
RULE 100 AND THEREFORE, IT WAS SUBJECT TO THE REQUIREMENTS OF
THE REGULATION AND OF FINRA RULE 5190(C). THE OFFERING PRICE
WAS DETERMINED AFTER THE CLOSE OF BUSINESS ON APRIL 30, 2009.
ACCORDINGLY, THE REGULATION M PERIOD FOR THE OFFERING BEGAN
ON APRIL 24, 2009 AND THE FIRM SHOULD HAVE RESTRICTED ITS
TRADING IN THE COMPANY AND THE SOLICITATION OF TRADES IN THAT
COMPANY'S SECURITIES BEGINNING ON THAT DATE. THE FIRM DID NOT.
AS A RESULT, WHEN THE OFFERING WAS CANCELED FOLLOWING
DISCOVERY BY THE FIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURE
Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.
TO FILE THE RESTRICTED PERIOD NOTIFICATION FORM, THE FIRM

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User Guidance

DISCOVERY BY THE FIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURE


TO FILE THE RESTRICTED PERIOD NOTIFICATION FORM, THE FIRM
THROUGH ITS AGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19
CUSTOMER PURCHASES, AND A FIRM REGISTERED REPRESENTATIVE
IMPROPERLY MADE TWO PURCHASE OF THE STOCK FOR HIS OWN
ACCOUNT. AS A RESULT, THE FIRM WILLFULLY VIOLATED SEC
REGULATION M, RULE 101, AND FINRA RULES 2010 AND 5190(C)(1)(A). THE
FIRM FAILED TO CAPTURE THE TIMES OF ITS RECEIPTS OF CUSTOMER
ORDERS. AS A RESULT, THE FIRM WILLFULLY VIOLATED SECTION 17(A) OF
THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4
THEREUNDER, FINRA RULE 2010, AND NASD RULES 2110 AND 3110(A). AS
IMPLEMENTED BY THE FIRM'S ANTI-MONEY LAUNDERING (AML)
COMPLIANCE OFFICER, THE FIRM'S AML POLICIES, PROCEDURES AND
INTERNAL CONTROLS WERE NOT REASONABLY DESIGNED TO ACHIEVE
COMPLIANCE WITH THE BANK SECRECY ACT (BSA) AND ITS
IMPLEMENTING REGULATIONS. THE FIRM, THROUGH ITS AML
COMPLIANCE OFFICER, FAILED TO ADEQUATELY IMPLEMENT ITS
CUSTOMER IDENTIFICATION PROGRAM (CIP) IN THAT IT FAILED TO
DOCUMENT THAT IT A) HAD OBTAINED CERTAIN REQUIRED PIECES OF
INFORMATION TO VERIFY THE CUSTOMER'S IDENTITY IN FIVE OF 51
ACCOUNTS SAMPLED BY FINRA'S EXAMINATION STAFF, B) HAD
PERFORMED ANY VERIFICATION OF THE CUSTOMER'S IDENTITY AT ALL IN
16 OF 51 ACCOUNTS SAMPLED, AND C) HAD PERFORMED THE REQUIRED
NON-DOCUMENTARY VERIFICATION FOR 28 ACCOUNTS. THE FIRM FAILED
TO ESTABLISH AND ENFORCE AN ADEQUATE AML COMPLIANCE
PROGRAM AND FAILED TO PROVIDE FOR INDEPENDENT TESTING FOR
COMPLIANCE WITH ITS AML OBLIGATIONS. THE FIRM FAILED TO REPORT
CUSTOMER COMPLAINTS NO LATER THAN THE 15TH DAY FOLLOWING THE
END OF THE CALENDAR QUARTER IN WHICH THOSE COMPLAINTS WERE
RECEIVED. THE FIRM IMPROPERLY PERMITTED OPTIONS TRADING,
FAILED TO RETAIN OPTION AGREEMENTS, AND FAILED TO OBTAIN
ESSENTIAL INFORMATION ON THE CLIENT OPTION AGREEMENT IN
CUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH, MAINTAIN AND
ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY
DESIGNED TO ACHIEVE COMPLIANCE WITH SEC REGULATION M, RULES
100 THROUGH 105 AND FINRA RULE 5190. THE FIRM ALSO FAILED TO
ENFORCE WSPS TO SUPERVISE ITS REGISTERED REPRESENTATIVES.
SPECIFICALLY, THE FIRM FAILED TO CONDUCT TRANSACTION REVIEWS
AND FAILED TO ESTABLISH AND ENFORCE HEIGHTENED SUPERVISION.
THE FIRM'S CHIEF EXECUTIVE OFFICER WAS REQUIRED TO SIGN, ON
BEHALF OF THE FIRM, THE CHIEF EXECUTIVE OFFICER CERTIFICATIONS
CERTIFYING THE FIRM'S WRITTEN COMPLIANCE POLICIES AND WSPS. THE
CHIEF EXECUTIVE OFFICER FAILED TO SIGN SUCH CERTIFICATIONS FOR
THE YEARS 2008 AND 2009.
Initiated By:
2015 FINRA. All rights reserved.

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

19

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User Guidance

Date Initiated:

05/31/2012

Docket/Case Number:

2008011743303

Principal Product Type:

Other

Other Product Type(s):

PRIVATE PLACEMENTS

Principal Sanction(s)/Relief
Sought:

Other

Other Sanction(s)/Relief
Sought:

N/A

Resolution:

Decision & Order of Offer of Settlement

Resolution Date:

03/25/2013

Does the order constitute a


final order based on
violations of any laws or
regulations that prohibit
fraudulent, manipulative, or
deceptive conduct?
Sanctions Ordered:

No

Censure
Monetary/Fine $50,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRM


CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF
FINDINGS THAT IT VIOLATED SECTION 17(A) OF THE SECURITIES
EXCHANGE ACT OF 1934, RULES 17A-3 AND 17A-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),
3011(C), 3013, 3110(A), AND 3070(C), THEREFORE THE FIRM IS CENSURED
AND FINED $50,000. FINRA IMPOSED A LOWER FINE IN THIS CASE AFTER
IS CONSIDERED, AMONG OTHER THINGS, THE FIRM'S REVENUES AND
FINANCIAL RESOURCES.

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

2015 FINRA. All rights reserved.

SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES


17A-3, 17A-4 THEREUNDER, SEC REGULATION M, RULE 101, FINRA RULES
2010, 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 FIRM
FAILED TO FILE AN SEC REGULATION M RESTRICTED PERIOD
NOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENT
Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.
OFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERING

20

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2015 FINRA. All rights reserved.

User Guidance

NOTIFICATION FORM IN CONNECTION WITH A PRIVATE PLACEMENT


OFFERING IT COMMENCED ON BEHALF OF A COMPANY. THE OFFERING
WAS SUBJECT TO THE REQUIREMENTS OF THE REGULATION AND OF
FINRA RULE 5190(C). THE OFFERING PRICE WAS DETERMINED AFTER THE
CLOSE OF BUSINESS ON APRIL 30, 2009. ACCORDINGLY, THE
REGULATION M PERIOD FOR THE OFFERING BEGAN ON APRIL 24, 2009
AND THE FIRM SHOULD HAVE RESTRICTED ITS TRADING IN THE
COMPANY AND THE SOLICITATION OF TRADES IN THAT COMPANY'S
SECURITIES BEGINNING ON THAT DATE. THE FIRM DID NOT. AS A RESULT,
WHEN THE OFFERING WAS CANCELED FOLLOWING DISCOVERY BY THE
FIRM'S OUTSIDE COUNSEL OF THE FIRM'S FAILURE TO FILE THE
RESTRICTED PERIOD NOTIFICATION FORM, THE FIRM THROUGH ITS
AGENTS AND EMPLOYEES, IMPROPERLY SOLICITED 19 CUSTOMER
PURCHASES, AND A FIRM REGISTERED REPRESENTATIVE IMPROPERLY
MADE TWO PURCHASE OF THE STOCK FOR HIS OWN ACCOUNT. AS A
RESULT, THE FIRM VIOLATED SEC REGULATION M, RULE 101, AND FINRA
RULES 2010 AND 5190(C)(1)(A). THE FIRM FAILED TO CAPTURE THE TIMES
OF ITS RECEIPTS OF CUSTOMER ORDERS. AS A RESULT, THE FIRM
VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934
AND RULES 17A-3 AND 17A-4 THEREUNDER, FINRA RULE 2010, AND NASD
RULES 2110 AND 3110(A). AS IMPLEMENTED BY THE FIRM'S ANTI-MONEY
LAUNDERING (AML) COMPLIANCE OFFICER, THE FIRM'S AML POLICIES,
PROCEDURES AND INTERNAL CONTROLS WERE NOT REASONABLY
DESIGNED TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT
(BSA) AND ITS IMPLEMENTING REGULATIONS. THE FIRM FAILED TO
ADEQUATELY IMPLEMENT ITS CUSTOMER IDENTIFICATION PROGRAM
(CIP) IN THAT IT FAILED TO DOCUMENT THAT IT A) HAD OBTAINED
CERTAIN REQUIRED PIECES OF INFORMATION TO VERIFY THE
CUSTOMER'S IDENTITY IN FIVE OF 51 ACCOUNTS SAMPLED BY FINRA'S
EXAMINATION STAFF, B) HAD PERFORMED ANY VERIFICATION OF THE
CUSTOMER'S IDENTITY AT ALL IN 16 OF 51 ACCOUNTS SAMPLED, AND C)
HAD PERFORMED THE REQUIRED NON-DOCUMENTARY VERIFICATION
FOR 28 ACCOUNTS. THE FIRM FAILED TO ESTABLISH AND ENFORCE AN
ADEQUATE AML COMPLIANCE PROGRAM AND FAILED TO PROVIDE FOR
INDEPENDENT TESTING FOR COMPLIANCE WITH ITS AML OBLIGATIONS.
THE FIRM FAILED TO REPORT CUSTOMER COMPLAINTS NO LATER THAN
THE 15TH DAY FOLLOWING THE END OF THE CALENDAR QUARTER IN
WHICH THOSE COMPLAINTS WERE RECEIVED. THE FIRM IMPROPERLY
PERMITTED OPTIONS TRADING, FAILED TO RETAIN OPTION AGREEMENTS,
AND FAILED TO OBTAIN ESSENTIAL INFORMATION ON THE CLIENT OPTION
AGREEMENT IN CUSTOMER ACCOUNTS. THE FIRM FAILED TO ESTABLISH,
MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS)
REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SEC
REGULATION M, RULES 100 THROUGH 105 AND FINRA RULE 5190. THE
FIRM ALSO FAILED TO ENFORCE WSPS TO SUPERVISE ITS REGISTERED
REPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO CONDUCT
Report# TRANSACTION
75052-63374 about FORDHAM
MANAGEMENT,
INC. Data current
as of Monday, January 26, 2015.
REVIEWSFINANCIAL
AND FAILED
TO ESTABLISH
AND ENFORCE
HEIGHTENED SUPERVISION. THE FIRM'S CHIEF EXECUTIVE OFFICER WAS

21

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User Guidance

REPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO CONDUCT


TRANSACTION REVIEWS AND FAILED TO ESTABLISH AND ENFORCE
HEIGHTENED SUPERVISION. THE FIRM'S CHIEF EXECUTIVE OFFICER WAS
REQUIRED TO SIGN, ON BEHALF OF THE FIRM, THE CHIEF EXECUTIVE
OFFICER CERTIFICATIONS CERTIFYING THE FIRM'S WRITTEN
COMPLIANCE POLICIES AND WSPS. THE CHIEF EXECUTIVE OFFICER
FAILED TO SIGN SUCH CERTIFICATIONS FOR THE YEARS 2008 AND 2009.
Initiated By:

FINRA

Date Initiated:

05/31/2012

Docket/Case Number:

2008011743303

Principal Product Type:

Other

Other Product Type(s):

PRIVATE PLACEMENT

Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Decision & Order of Offer of Settlement

Resolution Date:

03/25/2013

Sanctions Ordered:

Censure
Monetary/Fine $50,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM


CONSENTED TO THE DESCRIBED SANTCTIONS AND TO THE ENTRY OF
FINDINGS THAT IT VIOLATED SECTION 17(A) OF THE SEA OF 1934, RULES
17A-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 AND
FINED $50,000.

i
Disclosure 3 of 7
Reporting Source:

Regulator

Current Status:

Final

Allegations:

NASD RULES 2110, 3070 - FORDHAM FINANCIAL MANAGEMENT, INC.,


ACTING THROUGH AN INDIVIDUAL, FAILED TO REPORT STATISTICAL AND
SUMMARY INFORMATION REGARDING CUSTOMER COMPLAINTS AS
REQUIRED BY NASD RULE 3070(C).

Initiated By:

2015 FINRA. All rights reserved.

NASD

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

22

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User Guidance

Initiated By:

NASD

Date Initiated:

05/31/2006

Docket/Case Number:

E102005014702

Principal Product Type:

No Product

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

05/31/2006

Does the order constitute a


final order based on
violations of any laws or
regulations that prohibit
fraudulent, manipulative, or
deceptive conduct?
Sanctions Ordered:

No

Censure
Monetary/Fine $15,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED


TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS CENSURED AND FINED $15,000, JOINTLY AND
SEVERALLY.

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

WITHOUT ADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIAL


MANAGEMENT AND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE
FAILED TO REPORT (6) EMAIL AND FAX STATISTICAL CUSTOMER
COMPLAINTS ON 3070 FILE

Initiated By:

NASD

Date Initiated:

05/30/2006

Docket/Case Number:

E102005014702

Principal Product Type:


2015 FINRA. All rights reserved.

Other
Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

23

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User Guidance

Principal Product Type:

Other

Other Product Type(s):

STATISTICAL INFORMATION COMPLAINTS

Principal Sanction(s)/Relief
Sought:

Other

Other Sanction(s)/Relief
Sought:

LETTER OF ACCEPTANCE WAIVER AND CONSENT "AWC" WITHOUT


ADMIOTTING OR DENYING ALLEGATIONS FRODHAM FINANCIAL
MANAGEMENT AND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE
FAILED 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 THE
1SR QTR 2005. ON THE FIRM 3070 CUSTOMER COMPLAINT FILE.

Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

05/31/2006

Sanctions Ordered:

Censure
Monetary/Fine $15,000.00

Other Sanctions Ordered:


Sanction Details:

FINED AND CENSURED JOINTLY HARVEY LATZEN AND FORDHAM


FINANCIAL MANAGEMENT $15,000.00 OF WHICH TOTAL WAS PAID BY
FORDHAM FINANCIAL MANAGEMENT.

Firm Statement

WITHOUT ADMITTING OR DENYING A LETTER OF ACCEPTANCE WAIVER


AND CONSENT HAS NOW BEEN ACCEPTED BY NASD (NAC REVIEW
COMMITTEE).

i
Disclosure 4 of 7
Reporting Source:

Regulator

Current Status:

Final

Allegations:

NASD CONDUCT RULES 2110 AND 3070 - FORDHAM FINANCIAL


MANAGEMENT, INC., ACTING THROUGH HIS AN INDIVIDUAL, FAILED TO
REPORT STATISTICAL AND SUMMARY INFORMATION REGARDING
CUSTOMER COMPLAINTS, AS REQUIRED BY NASD CONDUCT RULE
3070(C).

Initiated By:

NASD

Date Initiated:

03/02/2005

Docket/Case Number:

C10050007

Principal Product Type:

No Product

Other Product Type(s):


Principal Sanction(s)/ReliefReport# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.
Sought:

2015 FINRA. All rights reserved.

24

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User Guidance

Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

03/02/2005

Does the order constitute a


final order based on
violations of any laws or
regulations that prohibit
fraudulent, manipulative, or
deceptive conduct?
Sanctions Ordered:

No

Censure
Monetary/Fine $8,000.00

Other Sanctions Ordered:


Sanction Details:

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT


FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY
OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $8,000,
JOINTLY AND SEVERALLY.

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

WITHOUT ADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIAL


AND HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE FAILED TO
REPORT STATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THESE
PARTICULAR COMPLAINTS WERE INSTEAD CARRIED AS
CORRESPONDENCE IN CORRESPONDENCE FILE.

Initiated By:

NASD

Date Initiated:

01/21/2005

Docket/Case Number:

C10050007

Principal Product Type:

Other

Other Product Type(s):

STATISTICAL INFORMATION CUSTOMER COMPLAINTS FILINGS.

Principal Sanction(s)/Relief
Sought:

Other

Other Sanction(s)/Relief
Sought:
2015 FINRA. All rights reserved.

LETTER OF ACCEPTANCE WAIVER AND CONSENT "AWC" WITHOUT


ADMITTING OR DENYING ALLEGATIONS FORDHAM FINANCIAL AND
LATZEN
JOINTLY
WERE MANAGEMENT,
ALLEGED TOINC.
HAVE
REPORT
Report# HARVEY
75052-63374
about FORDHAM
FINANCIAL
Data FAILED
current as TO
of Monday,
January 26, 2015.
STATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THE ALLEGED

25

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User Guidance

Other Sanction(s)/Relief
Sought:
HARVEY LATZEN JOINTLY WERE ALLEGED TO HAVE FAILED TO REPORT
STATISTICAL CUSTOMER COMPLAINTS ON 3070 FILE. THE ALLEGED
PARTICULAR COMPLAINTS WERE CARRIED IN THE CORRESPONDENCE
FILE.
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

03/02/2005

Sanctions Ordered:

Censure
Monetary/Fine $8,000.00

Other Sanctions Ordered:


Sanction Details:

FINED JOINTLY AND CENSURED HARVEY LATZEN AND FORDHAM


FINANCIAL $8,000.00
TOTAL PAID BY FORDHAM FINANCIAL MANAGEMENT.

Firm Statement

WITHOUT ADMITTING OR DENYING A LETTER OF ACCEPTANCE WAIVER


AND CONSENT HAS NOW BEEN ACCEPTED BY NASD (NAC)REVIEW
COMMITTEE.

i
Disclosure 5 of 7
Reporting Source:

Regulator

Current Status:

Final

Allegations:

EMPLOYING AN UNLICENSED AGENT; FAILURE TO SUPERVISE; FAILURE


TO MAINTAIN AND PROVIDE BOOKS AND RECORDS; DISHONEST AND
UNETHICAL BUSINESS PRACTICES BY NOT PROPERLY MAINTAINING AND
REPORTING CUSTOMER COMPLAINTS AND CORRESPONDENCE.

Initiated By:

UTAH DIVISION OF SECURITIES

Date Initiated:

04/03/2002

Docket/Case Number:

SD-02-0063

Principal Product Type:

Other

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:

Revocation

Other Sanction(s)/Relief
Sought:

FINE

Resolution:

Stipulation and Consent

Resolution Date:

02/11/2003

Sanctions Ordered:
2015 FINRA. All rights reserved.

Monetary/Fine $15,000.00
Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

26

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User Guidance

Sanctions Ordered:

Monetary/Fine $15,000.00

Other Sanctions Ordered:


Sanction Details:

FINE OF $15,000.00 TO BE PAID AS FOLLOWS: $3,000 UPON EXECUTION


OF THE STIPULATION AND CONSENT ORDER; $1,000 EVERY 30 DAYS FOR
TEN 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 UTAH
DIVISION OF SECURITIES, TO INVEST IN FOUNDRY NETWORKS WHILE HE
DID NOT HAVE A SECURITIES LICENSE IN UTAH. ANOTHER AGENT OF THE
FIRM, JOSEPH SCALI, SPOKE TO THE UTAH RESIDENT AND MISSTATED
MATERIAL FACTS. FROM DECEMBER 11-12, 2001, THE DIVISION
CONDUCTED AN AUDIT OF FORDHAM. DURING THE COURSE OF THE
AUDIT, THE DIVISION FOUND THAT FORDHAMS BOOKS AND RECORDS
WERE IMPROPERLY MAINTAINED. FOR MORE INFORMATION, PLEASE
VISIT THE DIVISION'S WEB SITE AT:
HTTP://WWW.SECURITIES.STATE.UT.US/ACTIONSEVENTS.ASP?
DOCKET+NUMBER=SD%2D02%2D0063

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

FAILURE TO SUPERVISE

Initiated By:

STATE OF UTAH DIVISION OF SECURITIES

Date Initiated:

04/03/2002

Docket/Case Number:

SD-02-0063

Principal Product Type:

Equity - OTC

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:

Other

Other Sanction(s)/Relief
Sought:

WITHOUT ADMITTING OR DENYING INVESTIGATIVE CONCLUSIONS,


CONSENTED TO PAY A FINE OF $15,000.00

Resolution:

Stipulation and Consent

Resolution Date:

02/10/2003

Sanctions Ordered:

Monetary/Fine $15,000.00

Other Sanctions Ordered:


Sanction Details:
2015 FINRA. All rights reserved.

WITHOUT ADMITTING OR DENYING THE SUBSTANCE OF INVESTIGATIVE


TO AN
ORDER REQUIRING
THAT
Report# CONCLUSION,CONSENTED
75052-63374 about FORDHAM FINANCIAL
MANAGEMENT,
INC. Data current
as FORDHAM
of Monday, January 26, 2015.
PAY A FINE OF $15,000.00

27

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User Guidance

Sanction Details:
CONCLUSION,CONSENTED TO AN ORDER REQUIRING THAT FORDHAM
PAY A FINE OF $15,000.00
Firm Statement

NEWLY REGISTERED INDIVIDUAL CALLED STATE. WAS NOT LICENSED IN


STATE. SPOKE TO STATE REGULATOR. REPS LICENSE WAS TWO WEEKS
OLD. REP WAS REPRIMANDED BY FIRM AND PUT ON NOTICE.
COMPLIANCE DEPT REVIEWED FIRM POLICY AND REGULATIONS ABOUT
BEING LICENSED IN STATE PRIOR TO CALLING WITH REP. FIRM SPOKE TO
REGULATOR AND REPLIED IN WRITING. FORDHAM FINANCIAL NEITHER
ADMITS NOR DENIES THE SUBSTANCE OF THE DIVISIONS(UTAH'S)
INVESTIGATIVE CONCLUSIONS, BUT CONSENTED TO THE DIVISIONS
ENTERING AND ORDER REQUIRING FORDHAM PAY A FINE OF $15,000.00

i
Disclosure 6 of 7
Reporting Source:

Regulator

Current Status:

Final

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 AND
NON-NASDAQ TRANSACTIONS WITHIN 20 MINUTES;FAILED TO SUBMIT
WITHIN 90 SECONDS AFTER EXECUTION LAST SALE REPORTS OF
NASDAQ NMS TRANSACTIONS AND CQS SECURITIES AND FAILED TO
DESIGNATE TRADES AS LATE WITH THE APPROPRIATE .SLD MODIFIER
AND FOR ONE CQS TRANSACTION, THE TRANSACTION REPORT
CONTAINED THE INCORRECT VOLUME; AND FAILED TO ACCEPT OR
DECLINE TRANSACTIONS WITHIN 20 MINUTES OF EXECUTION.

Initiated By:

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated:

05/30/2000

Docket/Case Number:

C10000085

Principal Product Type:

Other

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:
Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

05/30/2000

Sanctions Ordered:

Monetary/Fine $3,000.00

Other Sanctions Ordered:


2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

28

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User Guidance

Other Sanctions Ordered:


Sanction Details:

FINED $3,000

i
Reporting Source:

Firm

Current Status:

Final

Allegations:

THE ALLEGATION WAS MEMBER FAILED TO ACCEPT OR DECLINE NASDAQ


AND NON-NASDAQ TRANSACTION WITHIN TWENTY MINUTES, FAILED TO
SUBMIT WITHIN NINETY SECONDS AFTER EXECUTION REPORTS OF
NASDAQ NMS TRANSACTIONS.

Initiated By:

NATIONAL ASSOCIATION OF SECURITIES DEALERS

Date Initiated:

05/30/2000

Docket/Case Number:

C10000085

Principal Product Type:

Other

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:

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

Other Sanction(s)/Relief
Sought:
Resolution:

Acceptance, Waiver & Consent(AWC)

Resolution Date:

05/30/2000

Sanctions Ordered:

Monetary/Fine $3,000.00

Other Sanctions Ordered:


Sanction Details:

FINED $3,000.00

Firm Statement

FORDHAM FINANCIAL MANAGEMENT, INC. HAS ACCEPTED AND


CONSENTED WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.
WHEN THESE ALLEGATIONS WERE BROUGHT TO THE FIRMS ATTENTION
THE FIRM'S OBLIGATION WAS TO REVIEW THESE ALLEGATIONS WITH THE
FIRM'S TRADING PERSONNEL, UNFORTUNATELY THE TRADING
INDIVIDUALS WERE NO LONGER WITH THE FIRM. CURRENTLY ALL
TRADING EMPLOYEES ARE REQUIRED TO REVIEW MARKET
MAKING/TRADING PROCEDURES AND TO INITIAL A COPY TO INSURE
FAMILIARITY.

i
Disclosure 7 of 7
2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

29

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User Guidance

Reporting Source:

Regulator

Current Status:

Final

Allegations:

THE SUBJECT FIRM ENGAGED IN BROKER/DEALER ACTIVITIES IN THE


STATE OF NORTH DAKOTA WITHOUT REGISTRATION IN NORTH DAKOTA.
THE SUBJECT FIRM PROVIDED FALSE INFORMATION TO THE
COMMISSIONER WHEN THEY DENIED THAT THEY OFFERED FOR SALE
AND/OR SOLD SECURITIES IN NORTH DAKOTA. THE SUBJECT FIRM WAS
NOT OF A GOOD BUSINESS REPUTATION BECAUSE OF THE DISCIPLINARY
HISTORY OF ITS PRESENT.

Initiated By:

THE OFFICE OF THE NORTH DAKOTA SECURITIES COMMISSIONER.

Date Initiated:

07/22/1999

Docket/Case Number:
Principal Product Type:

Other

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:

Denial

Other Sanction(s)/Relief
Sought:
Resolution:

Order

Resolution Date:

10/19/1999

Sanctions Ordered:

Revocation/Expulsion/Denial

Other Sanctions Ordered:


Sanction Details:

THE PENDING BROKER/DEALER APPLICATION OF THE SUBJECT FIRM WAS


DENIED.

Regulator Statement

THE SUBJECT FIRM ENGAGED IN BROKER/DEALER ACTIVITIES IN THE


STATE OF NORTH DAKOTA WITHOUT REGISTRATION IN NORTH DAKOTA.
THE SUBJECT FIRM PROVIDED FALSE INFORMATION TO THE
COMMISSIONER WHEN THEY DENIED THAT THEY OFFERED FOR SALE
AND/OR SOLD SECURITIES IN NORTH DAKOTA. THE SUBJECT FIRM WAS
NOT OF A GOOD BUSINESS REPUTATION BECAUSE OF THE DISCIPLINARY
HISTORY OF ITS PRESENT.

i
Reporting Source:

Firm

Current Status:

Final

Allegations:
2015 FINRA. All rights reserved.

THE STATE OF NORTH DAKOTA ALLEGED THAT FORDHAM FINANCIAL HAD


SECURITIES
TO AFINANCIAL
SINGLE CLIENT
WITHIN
NORTH
Report# SOLD
75052-63374
about FORDHAM
MANAGEMENT,
INC.THE
Data STATE
current asOF
of Monday,
January 26, 2015.
DAKOTA WITHOUT REGISTRATION IN THE STATE. FORDHAM DENIED THE

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User Guidance

Allegations:

THE STATE OF NORTH DAKOTA ALLEGED THAT FORDHAM FINANCIAL HAD


SOLD SECURITIES TO A SINGLE CLIENT WITHIN THE STATE OF NORTH
DAKOTA WITHOUT REGISTRATION IN THE STATE. FORDHAM DENIED THE
ALLEGATIONS AND THE STATE FURTHER ALLEGED THAT FORDHAM
PROVIDED FALSE INFORMATION IN CONNECTION WITH THIS DENIAL.

Initiated By:

THE STATE OF NORTH DAKOTA

Date Initiated:

07/22/1999

Docket/Case Number:
Principal Product Type:

No Product

Other Product Type(s):


Principal Sanction(s)/Relief
Sought:

Revocation

Other Sanction(s)/Relief
Sought:
Resolution:

Order

Resolution Date:

10/19/1999

Sanctions Ordered:

Revocation/Expulsion/Denial

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. IN


RESPONSE TO THIS APPLICATION, THE STATE CONTACTED FORDHAM'S
CLEARING FIRM TO INQUIRE WHETHER ANY SALES HAD BEEN
CONDUCTED IN NORTH DAKOTA. UNBEKNOWNST TO FORDHAM, A
FORDHAM CLIENT WHO HAD PREVIOUSLY RESIDED IN A NEIGHBORING
STATE IN WHICH FORDHAM WAS REGISTERED HAD CHANGED HIS
MAILING ADDRESS TO NORTH DAKOTA. UNAWARE OF THIS, FORDHAM
SOLD SECURITIES TO THIS CUSTOMER IN NORTH DAKOTA. THE CLIENT
AND BROKER CONFIRMED THESE FACTS TO NORTH DAKOTA
REGULATORS IN WRITING. DESPITE THIS, AND DESPITE EXTENSIVE
EFFORTS TO RESOLVE THIS MATTER BY FORDHAM, NORTH DAKOTA
PROCEEDED TO ENTER AN ORDER ON DEFAULT AGAINST FORDHAM,
DENYING LICENSING. FORDHAM REAPPLIED FOR LICENSE AND WAS
GRANTED IN THE STATE 3/11/02.

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

31

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User Guidance

Arbitration Award - Award/Judgment


Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheck
provides summary information regarding FINRA arbitration awards involving securities and commodities disputes
between 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
Reporting Source:

Regulator

Type of Event:

ARBITRATION

Allegations:

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT


RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS;
ACCOUNT RELATED-NEGLIGENCE

Arbitration Forum:

NASD

Case Initiated:

11/16/2000

Case Number:

00-05020

Disputed Product Type:

UNKNOWN TYPE OF SECURITIES

Sum of All Relief Requested:

$73,205.14

Disposition:

AWARD AGAINST PARTY

Disposition Date:

08/05/2002

Sum of All Relief Awarded:

$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.

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

32

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User Guidance

End of Report

This page is intentionally left blank.

2015 FINRA. All rights reserved.

Report# 75052-63374 about FORDHAM FINANCIAL MANAGEMENT, INC. Data current as of Monday, January 26, 2015.

33

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