Searle & Co.

Allegations: THE STAFF ALLEGES THAT THE FIRM VIOLATED CERTAIN REPORTING REQUIREMENTS AND LACKED A SUFFICIENT SUPERVISORY SYSTEM RELATING TO THE ORDER AUDIT TRAIL SYSTEM ("OATS") FROM JANUARY 1, 2007, THROUGH DECEMBER 31, 2008. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $12,500 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING OATS REPORTING WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.

Allegations: FINRA RULE 2010, NASD RULES 2110, 2330, 3010: THE FIRM, ACTING THROUGH ITS PRESIDENT AND CHIEF COMPLIANCE OFFICER, SHARED PROFITS IN THE ACCOUNT OF A CUSTOMER OF ANOTHER FINRA MEMBER AND THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATED TO SHARING IN PROFITS AND LOSSES IN CUSTOMER ACCOUNTS OF FINRA MEMBERS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $5,000, AND FINED $10,000, JOINTLY AND SEVERALLY.

Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, RULES 17A-3, 17A-4 AND 17A-5 THEREUNDER, NASD BY-LAWS ARTICLE IV, SECTION 1(C), NASD RULES 2110, 2420, 3010, 3110: FIRM FAILED TO UPDATE FORM BD IN TIMELY FASHION; FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SYSTEM AND WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE ITS PLACEMENT BUSINESS; FAILED TO ADEQUATELY SUPERVISE THE PLACEMENT BUSINESS CONDUCTED AT AN UNREGISTERED OFFICE; DUE TO AN IMPERMISSIBLE ACCOUNTING CONVENTION, FAILED TO ADEQUATELY ENSURE THAT ITS LEDGERS OR OTHER RECORDS ACCURATELY REFLECTED ALL ASSETS, LIABILITIES, INCOME AND EXPENSES OF THE FIRM, AND AS A CONSEQUENCE, FILED INACCURATE FOCUS REPORTS AND ANNUAL FINANCIAL AUDIT REPORTS; AND IMPROPERLY PAID REGISTERED REPRESENTATIVES VIA THEIR SOLE MEMBER LLC'S (NON-REGISTERED ENTITIES) RATHER THAN DIRECTLY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED AND FINED $47,500, OF WHICH $10,000 IS JOINT AND SEVERAL.