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1
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SEC COMMISSION OPINION
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EXTRACTED KEY WORDS
GERHAUSER MARGIN ACCOUNTS SECURITIES EXCHANGE ACT VIOLATION EXCHANGE ACT FIRM SANCTIONS RGI COMMISSION DEFICITS SGSC FINDINGS CLEARING AGREEMENT APPLICANTS PRINCIPALS NATIONAL ASSOCIATION BROKER-DEALER RESPONSIBILITY SECURITIES DEALERS INTRODUCING BROKER-DEALER MEMBER FIRM FINOP REGULATIONS DEBIT BALANCES NET CAPITAL DEFICIENCY FAIR PRACTICE REPORTING REQUIREMENTS FOCUS REPORTS RECORDKEEPING |
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C.
SECURITIES EXCHANGE ACT OF 1934
Rel. No. 40639 / November 4, 1998
Admin. Proc. File No. 3-9519
_________________________________________________
:
In the Matter of the Application of :
:
WILLIAM H. GERHAUSER, Sr. :
:
and :
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WILLIAM C. GERHAUSER, Jr. :
:
For Review of Action Taken by the :
:
NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. :
:
:
OPINION OF THE COMMISSION
REGISTERED SECURITIES ASSOCIATION -- REVIEW OF DISCIPLINARY
PROCEEDINGS
Violations of Rules of Fair Practice
Failure to Comply with Net Capital,
Recordkeeping, and Reporting Requirements
President and registered financial and operations principal of
introducing broker-dealer member firm of registered securities association
failed to reduce firm's net capital by the known deficit in margin
accounts and thereby, violated net capital, recordkeeping and reporting
requirements. Held, association's findings of violations and the sanctions
it imposed are sustained.
APPEARANCES:
Daniel J. Dugan, of Spector Gadon & Rosen, P.C., for William H.
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