SEC v TIMOTHY MCCOOL RELEASE NOS.: 34-48575, AAER-1882


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Keywords & Phrases

CaseNo: 33-8296, Defendant: Timothy McCool Release Nos.: 34-48575, AAER-1882, Plaintiff: SEC, State: OR Oregon, UniqueCaseRef: SEC>33-8296, Act, Securities, Feet, Exchange Act, Mccool, Commission, Vendor, Confirmation, Advertising, Respondent, Cease-and-desist Proceedings, Pursuant, Violations, Instituting, Findings, Sales, Advertising Co-op, Audit Confirmation, Receivables, Financial Statements, Future Violations, Confirmation Letter, Reports, Thereunder, North American, Timothy Mccool, Amounts, Admitting, Merchandise, Advertising Expenses , ContentID: 120255593

Case Documents

2003-09-30

SEC ADMINISTRATIVE PROCEEDING
[ see first page and extracted highlights below ] ItemID: 132883

4 pages
HTML

Total Documents: 1 document , 4 pages

Price: $ 19.95

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1 . SEC ADMINISTRATIVE PROCEEDING

EXTRACTED KEY WORDS

SECURITIES
FEET
EXCHANGE ACT
MCCOOL
COMMISSION
VENDOR
CONFIRMATION
ADVERTISING
RESPONDENT
CEASE-AND-DESIST PROCEEDINGS
PURSUANT
VIOLATIONS
INSTITUTING
FINDINGS
SALES
ADVERTISING CO-OP
AUDIT CONFIRMATION
RECEIVABLES
FINANCIAL STATEMENTS
FUTURE VIOLATIONS
CONFIRMATION LETTER
REPORTS
THEREUNDER
NORTH AMERICAN
TIMOTHY MCCOOL
AMOUNTS
ADMITTING
MERCHANDISE
ADVERTISING EXPENSES

UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933
Release No. 8296 / September 30, 2003

SECURITIES EXCHANGE ACT OF 1934
Release No. 48575 / September 30, 2003

ACCOUNTING AND AUDITING ENFORCEMENT
Release No. 1882 / September 30, 2003

ADMINISTRATIVE PROCEEDING
File No. 3-11289
     _________________________________________________________________


   In the Matter of

   TIMOTHY McCOOL,

   Respondent.

     _________________________________________________________________

   ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND
   IMPOSING A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 8A OF THE
   SECURITIES ACT OF 1933 AND SECTION 21C OF THE SECURITIES EXCHANGE ACT
   OF 1934

                                     I.

   The Securities and Exchange Commission ("Commission") deems it
   appropriate that cease-and-desist proceedings be, and they hereby are,
   instituted pursuant to Section 8A of the Securities Act of 1933
   ("Securities Act") and Section 21C of the Securities Exchange Act of
   1934 ("Exchange Act") against Timothy McCool ("McCool" or the
   "Respondent").

                                    II.

   In anticipation of the institution of these proceedings, Respondent
   has submitted an Offer of Settlement (the "Offer") which the
   Commission has determined to accept. Solely for the purpose of these
   proceedings and any other proceedings brought by or on behalf of the
   Commission, or to which the Commission is a party, and without
   admitting or denying the findings herein, except as to the

SNIPPETS:

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING A

The Securities and Exchange Commission deems it appropriate that cease-and-desist proceedings

In anticipation of the institution of these proceedings, Respondent has submitted an Offer of

Solely for the purpose of these proceedings and any other proceedings brought by or on behalf the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, as set forth

Respondent Timothy McCool of Portland, Oregon, was the Director of Sales for the North

Most of its vendors offered financial assistance through unwritten agreements to Just for

When Just for Feet promoted a particular vendor's products in one of its advertisements, that

Just for Feet often deducted these amounts as credits against future payments it made to its

McCool, the Director of Sales for the North American subsidiary of the Vendor, signed on

The letter clearly stated that the confirmation was in connection with the audit of Just for

In fact, the Vendor owed no advertising co-op receivables to Just for Feet as of January 30,

but nonetheless signed and submitted the confirmation letter.

By the acts and practices described above, McCool caused Just for Feet to violate Section

McCool also caused Just for Feet to violate Section 13of the Exchange Act and Rules 12b-20,

Accordingly, it is hereby ORDERED that Respondent McCool cease and desist from committing or


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