UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 44407 / June 11, 2001
ADMINISTRATIVE PROCEEDING
File No. 3-10068
_________________________________________________________________
In the Matter of
Legg Mason Wood Walker, Incorporated
Thomas M. Daly, Jr., and
Joseph A. Sullivan,
Respondents
_________________________________________________________________
ORDER MAKING FINDINGS,
IMPOSING REMEDIAL
SANCTIONS, AND CEASE-AND-
DESIST ORDER
I.
In these proceedings instituted pursuant to Sections 15(b), 15B(c),
19(h) and 21C of the Securities Exchange Act of 1934 ("Exchange Act"),
Respondents Legg Mason Wood Walker, Incorporated ("Legg Mason"),
Thomas M. Daly, Jr. ("Daly") and Joseph A. Sullivan ("Sullivan")
(collectively, the "Respondents") have submitted Offers of Settlement
(the "Offers") which the Securities and Exchange Commission
("Commission") has determined to accept. Solely for the purpose of
these proceedings and any other proceeding brought by or on behalf of
the Commission or in which the Commission is a party, and without
admitting or denying the findings contained herein, except
jurisdiction, which each Respondent admits, the Respondents, by their
Offers, consent to the findings and the imposition of the sanctions
and other relief contained in this Order Making Findings and Imposing
Remedial Sanctions and Cease-and-Desist Order ("Order").
II.
On the basis of this Order and the Offers submitted by the
Respondents, the Commission finds that
A. Respondents
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
Legg Mason Wood Walker, Incorporated
Thomas M. Daly, Jr., and Joseph A. Sullivan,
In these proceedings instituted pursuant to Sections 15, 15B, 19and 21C of the Securities
and Joseph A. Sullivan have submitted Offers of Settlement which the Securities and Exchange
From, at least, June 30, 1994 to April 18, 1997, Daly managed Legg Mason's municipal
From June 30, 1994 through June 30, 1998, Legg Mason was the senior-managing or sole
At various times during the relevant time period, Legg Mason, Daly and, to a lesser extent,
From, at least, April 18, 1997 through February 1999, Sullivan supervised certain Legg Mason
MSRB Rule G-27 requires each broker, dealer and municipal securities dealer to supervise the
More specifically, MSRB Rule G-27requires each broker, dealer and municipal securities dealer
Subpart requires the designation of principals to be responsible for such supervision, and
maintenance and enforcement of written supervisory procedures reasonably designed to ensure
Finally, subpart imposes on the dealer the duty to revise and update written procedures as
From, at least, June 30, 1994 through April 18, 1997, Daly was a cause of Legg Mason's
Legg Mason shall, within 30 days of the entry of this Order, pay a civil money penalty in the
Such payment shall be made by United States postal money order, certified check, bank
cover letter and money order or check shall be sent to Ronald C.
Long, District Administrator, Philadelphia District Office, Securities and Exchange
Within 30 days of retention, the independent consultant shall review such policies,
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