ADMINISTRATIVE PROCEEDING v BRENNAN


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Keywords & Phrases

CaseNo: 33-7619, Defendant: BRENNAN, Plaintiff: ADMINISTRATIVE PROCEEDING, State: MA Massachusetts, UniqueCaseRef: SEC>33-7619, Investment, Fund, Brennan, Securities, Act, Money, Market, First Boston, Commission, Advisers, Portfolio, Exchange, Srns, Proceeding, Respondent, Management, Csfbimc, Findings, Offshore, Offering Circular, Clients, Purchaser, Violations, Reserve, Weighted Average Maturity, Misrepresentations, Materials, Unlawful, Dealer, Payment , ContentID: 120245534

Case Documents

1998-12-23

SEC ADMINISTRATIVE PROCEEDING
[ see first page and extracted highlights below ] ItemID: 112273

6 pages
HTML

Total Documents: 1 document , 6 pages

Price: $ 19.95

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1 . SEC ADMINISTRATIVE PROCEEDING

EXTRACTED KEY WORDS

FUND
BRENNAN
SECURITIES
ACT
MONEY
MARKET
FIRST BOSTON
COMMISSION
ADVISERS
PORTFOLIO
EXCHANGE
SRNS
PROCEEDING
RESPONDENT
MANAGEMENT
CSFBIMC
FINDINGS
OFFSHORE
OFFERING CIRCULAR
CLIENTS
PURCHASER
VIOLATIONS
RESERVE
WEIGHTED AVERAGE MATURITY
MISREPRESENTATIONS
MATERIALS
UNLAWFUL
DEALER
PAYMENT

UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION

   Securities Act of 1933
   Release No. 7619 / December 23, 1998

   Securities Exchange Act of 1934
   Release No. 40830 / December 23, 1998

   Investment Advisers Act of 1940
   Release No. 1778 / December 23, 1998

   Administrative Proceeding
   File No. 3-9716

   In the Matter of

   SEAN P. BRENNAN, and
   KEITH E. WALSH, Respondents.
   ORDER MAKING FINDINGS, IMPOSING

   REMEDIAL SANCTIONS AND CEASE-
   AND-DESIST ORDER

   I.

   Sean P. Brennan has submitted an Offer of Settlement for the purpose
   of disposing of the issues raised by this proceeding. 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, and
   prior to hearing and without admitting or denying the findings set
   forth herein, Brennan consents to the entry of this Order Making
   Findings, Imposing Remedial Sanctions and Cease-and-Desist Order
   ("Order"). The Commission has determined that it is appropriate and in
   the public interest to accept the Offer of Settlement from Brennan,
   and accordingly is issuing this Order.

   II.

   FACTS

   Based on the foregoing, the Commission finds that

   A. Respondent

   Sean P. Brennan, age 37, resides in Merrimackport, Massachusetts.
   During the relevant time, Brennan was the Vice President of Sales and

SNIPPETS:

SECURITIES AND EXCHANGE COMMISSION

Securities Exchange Act of 1934

Sean P. Brennan has submitted an Offer of Settlement for the purpose of disposing of the

Solely for the purposes of these proceedings and any other proceedings brought by or on

Brennan was the Vice President of Sales and Marketing for the Investment Management Group of

CSFBIMC was registered with the Commission as an investment adviser pursuant to the

During the fall of 1993, CSFBIMC made plans to create, develop and market an unregistered

Unlike a traditional money market fund subject to Rule 2a-7 under the Investment Company Act

CSFBIMC's internal planwas to have the Fund's securities portfolio consist of approximately

With input from Brennan and others, CSFBIMC prepared an offering circular, dated December 15,

In mid-December 1993, as final plans for launching the Fund were being made, Brennan asked

Prior to making the additional investment, the Investor requested, and Brennan agreed, that

Misleading Marketing Materials

Section 10of the Exchange Act and Rule 10b-5 thereunder make it unlawful to employ any

Based on these facts, Brennan willfully violated the antifraud provisions of the Securities

Brennan pay a civil money penalty of $50,000 within thirty days of the entry of the Order, by umber of this proceeding.

the terms of which are negotiated by the dealer and the purchaser.


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