UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 34-40922 / January 11, 1999
ADMINISTRATIVE PROCEEDING
File No. 3-9803
______________________________
:
In the Matter of : ORDER MAKING FINDINGS
: AND IMPOSING SANCTIONS
CERTAIN MARKET MAKING : AS TO RAYMOND JAMES &
ACTIVITIES ON NASDAQ : ASSOCIATES, INC.,
: THOMAS J. DUDENHOEFER
: AND TIMOTHY J. KANE
______________________________:
I.
In the accompanying Orders Instituting Proceedings
Pursuant to Sections 15(b) and 21C of the Securities
Exchange Act of 1934 and Findings of the Commission ("Order
Instituting Proceedings"), the Securities and Exchange
Commission ("Commission") instituted these public
administrative proceedings against Raymond James &
Associates, Inc., Thomas J. Dudenhoefer, Timothy J. Kane,
and other firms and individuals. Contemporaneously, Raymond
James & Associates, Inc., Thomas J. Dudenhoefer and Timothy
J. Kane ("Respondents") have submitted Offers of Settlement
("Offers") in anticipation of the institution of these
proceedings, which the Commission has determined to accept.
In their Offers, Respondents, solely for the purposes of
these proceedings and any other proceedings 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
herein, except for the findings of Section II.A., which are
admitted, have consented to the entry of the Order
Instituting Proceedings and this Order Making Findings and
Imposing Sanctions as to Raymond James & Associates, Inc.,
Thomas J. Dudenhoefer and Timothy J. Kane (which are
hereinafter referred to as the "Orders").
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
In the accompanying Orders Instituting Proceedings
Exchange Act of 1934 and Findings of the Commission ("Order
James & Associates, Inc., Thomas J. Dudenhoefer and Timothy
J. Kane have submitted Offers of Settlement
have consented to the entry of the Order
Imposing Sanctions as to Raymond James & Associates, Inc.,
Inc.'s principal place of business during the
James & Associates, Inc., traded Nasdaq stocks for its own
Florida and, at all relevant times, was a Nasdaq trader at
As a Nasdaq trader, Thomas
securities traded on the Nasdaq Stock Market.
related series of market making transactions in:
Order Instituting Proceedings in violation of Section
15of the Exchange Act and Rule 15c2-7 thereunder,
In 1994, Respondent Raymond James & Associates,
policies and procedures to prevent violations of the rules
By reason of the foregoing, Raymond James & Associates,
and committing or causing any future violation
civil penalty in the amount of $400,000 by wire
bank money order,
money order or check, to be sent to Leonard W.
Commission staff or the Independent Consultant (as
practices relating to prevention or detection of
Within three months of receiving recommendations
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