UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 43050 / July 18, 2000
ADMINISTRATIVE PROCEEDING
File No. 3-10255
_________________________________________________________________
In the Matter of
JANNEY MONTGOMERY
SCOTT LLC
and
NORMAN T. WILDE, JR.,
Respondent.
_________________________________________________________________
ORDER INSTITUTING PUBLIC
PROCEEDINGS, MAKING FINDINGS
AND IMPOSING REMEDIAL
SANCTIONS
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate and in the public interest that administrative proceedings
be instituted pursuant to Sections 15(b) and 19(h) of the Securities
Exchange Act of 1934 ("Exchange Act") against Janney Montgomery Scott
LLC ("Janney") and Norman T. Wilde, Jr. ("Wilde").
In anticipation of the institution of these proceedings, Janney and
Wilde have submitted Offers of Settlement ("Offers") that the
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 to which the Commission is a party, prior to a hearing
pursuant to the Commission's Rules of Practice, and without admitting
or denying the findings set forth herein, except that Janney and Wilde
admit the Commission's jurisdiction over them and over the subject
matter of these proceedings, Janney and Wilde consent to the entry of
this Order Instituting Public Proceedings, Making Findings and
Imposing Remedial Sanctions ("Order").
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
JANNEY MONTGOMERY SCOTT LLC
The Securities and Exchange Commission deems it appropriate and in the public interest that
Solely for the purpose of these proceedings and any other proceeding brought by or on behalf
ing Findings and Imposing Remedial Sanctions.
Janney, which is headquartered in Philadelphia, Pennsylvania, has over 50 branch offices
Janney is a wholly owned subsidiary of Independence Square Properties LLC, which is located
Mark Coleman Graves was employed, at all times relevant to this proceeding, as a registered
Unbeknownst to Janney management, from 1988 through July 1996, Graves willfully violated
Once the money had been transferred, Graves persuaded the customers to issue him checks by
In order to conceal his fraudulent acts, Graves sent false confirmations to customers, lied
In particular, three systems that should have detected irregularities failed to do so because
For example, had Janney employed adequate procedures, Graves' supervisors might have been
During the relevant time period, Janney had inadequate procedures to ensure that its outgoing
During the relevant time period, Janney had inadequate written procedures regarding the
at least one of Graves' customers sent the firm a letter detailing certain problems with an
Had the firm established adequate written guidelines for the identification and processing of
In April 1995, Janney engaged an independent consultant to review its policies and
In November 1996, the PSC issued an administrative order finding that Janney had violated
Such payment shall be made by United States postal money order, certified check, bank
tter and money order or check shall be sent to Ronald C.
Long, District Administrator, Philadelphia District Office, Securities and Exchange
Janney shall, within 1 year of the date of this Order, comply with its undertaking to retain,
s, procedures and practices, as described in Section II. B. 5., with a view to determining if all
The independent consultant shall prepare a written report of findings and recommendations
For the period of engagement and for a period of 1 year from the completion of the
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