Proceeding Number 2008011701203
Hearing Panel Decision in Department of Enforcement v. Daniel James Gallagher and Vision Securities Inc.
June 13, 2011
Respondent Gallagher was barred for violating: (1) Rules 8210 and 2010 by failing to answer questions during two OTRs; (2) Rules 1021(a) and 2110 by acting as an unregistered principal; and (3) Rule 2110 by circumventing heightened supervision that had been imposed on him by New York, New Jersey, Maryland and FINRA. Because of the bars, sanctions were not imposed against Gallagher for violating: (1) Rules 2110 and 2010 by willfully failing to amend his Form U4 to disclose an SEC complaint and judgment against him and (2) Rules 3012, 3013, and 2110 by failing to adopt and certify Vision’s compliance and supervisory processes. Respondent Vision Securities was censured and fined a total of $60,000 for violating: (1) Rules 1021(a) and 2110 by allowing Gallagher to act as an unregistered principal; (2) Rules 3010 and 2110 by failing to conduct heightened supervision of Gallagher; (3) Rules 3012, 3013, and 2110 by failing to adopt a supervisory control system and failing to annually certify Vision’s compliance and supervisory processes; (4) Rules 3070 and 2110 by failing to accurately report and maintain Rule 3070 filings and failing to update Forms U4 and U5; (5) Rules 3011(c) and 2110 by failing to conduct independent AML testing; and (6) Rules 1120(B)(2) and 2110 by failing to administer and document Vision’s continuing education program. The Respondents were also ordered to pay costs.
This decision has been appealed.
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