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the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.

1. Regulatory Action initiated by.

SEC Other Federal ©Sinto #520 © Kereign

(Full name of regulator, foreign financial regulatory authority, Federal, State, SRO or commodities exchange) NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

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7. Describe the allegations related to this regulatory action. (Your information must fit within the space provided.):

8. Current status?Prading On Appeal & Final

9. If on appeal, regulatory action appealed to: (SEC, SRO, Federal or State Court) and Date Appeal Filed:

.

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

Decision

11. Resolution Date (MM/DD/YYYY):

05/09/1991 Runct© Explanation

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C. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you, date paid and if any portion of penalty was waived:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates. (Your information must fit within the space provided.)

[TOP] COMPLAINT NUMBER PEL-847 (DISTRICT NO. 11) FILED 7/31/89 AGAINST HARVEY I HOUTKIN, ET AL. ALLEGING VIOLATIONS OF ART. II, SECT. 1, 4, 21(4), 27(a) & 33 OF THE RULES OF FAIR PRACTICE. HOUTKIN FAILED TO: 1) ACCURATELY PREPARE RECORDS; 2) PREPARE AN ACCURATE FOCUSI REPORT; 3) COMPLY WITH EXEMPTION FROM SEC RULE 1503-3; 4) MAKE DISCLOSURES ON CONFIRMATIONS; 5) ADOPT WRITTEN SUPERVISORY PROCEDURES IN BRANCH OFFICES, 6) PROMPTLY DEPOSIT LTD. PARTNERSHIP OFFERING FUNDS TO ESCROW ACCOUNT, 7) EFFECTED SECURITIES CUSTOMER'S TRANSACTIONS AT UNFAIR PRICES. FAILED TO: 8) MAINTAIN INFO. OF OPTION ACCOUNTS; 9) ACCEPT IN WRITING, BY A REGISTERED OPTIONS PRINCIPAL, DISCRETIONARY ACCOUNTS, 10) PROVIDE FOR APPROVAL INITIALING BY A REGISTERED OPTIONS PRINCIPAL OF DISCRETIONARY OPTIONS TRANSACTIONS, AND, 11) DEVELOP A WRITTEN SUPERVISORY PROGRAM OF OPTIONS ACCOUNTS AND TRANSACTIONS. DECISION 8/25/90, HOUTKIN, ET AL: ARE CENSURED, FINED $10,000 JOINTLY AND SEVERALLY (J+S), AND REQUIRED J+S TO PAY $10,975 TO CUSTOMERS HE MUST REQUALIFY AS GENERAL SECURITIES OR FINANCIAL AND OPERATIONS PRINCIPAL, AND ARE ASSESSED COSTS OF $1,002, J+S. THE COMMITTEE DISMISSED A PORTION OF COMPLAINTS: FAILURE TO PREPARE A CHECK RECORD AS FIRM DID NOT RECEIVE CHECKS TO RECORD, FAILURE TO DISCLOSE, AS THE FIRM COMPILED AND PROVIDED INFO FOR CONFIRMATIONS SUPERVISORY PROCEDURES, DIRECT PARTICIPATION PROGRAMS AS IT WAS UNABLE TO CONCLUDE THAT FIRM HAD TO DEPOSIT/FORWARD INVESTOR FUNDS IN ESCROW ACCOUNT, AND VARIOUS OPTIONS VIOLATIONS. 9/5/90 - HOUTKIN APPEALED TO THE BOARD OF GOVERNORS (BOG). DECISION RENDERED 49/91, C9A890004 (PEL-847) FINDINGS AND SANCTIONS MODIFIED, SO HOUTKIN, ET AL. ARE CENSURED, FINED $1,000, J+S, PLUS DBCC COSTS OF $1,002, J+S; HOUTKIN IS RELIEVED FROM OBLIGATION TO REQUALIFY BOG REVERSED DBCCS FINDINGS WITH REGARD TO THE 7TH CAUSE. 5/9/91 - DECISION IS FINAL. ***$2,002.00 J&S PAID ON 4/30/91 INVOICE #91-9A-486***

Individual CRD#: 251066

Legacy Disclosure Occurrence Details

Individual Name: HOUTKIN, HARVEY I

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