Royal Palms Capital, Llc

Allegations: ALLEGED THAT ADVISORY AFFILIATE, KRISTIN HETZER, ENGAGED IN UNETHICAL CONDUCT IN VIOLATION OF NASD CONDUCT RULE 2110. Status: Final Sanction Detail: "RESPONDENT RECEIVED A SUSPENSION FROM ASSOCIATING WITH ANY NASD MEMBER IN ALL CAPABILITIES FOR A PERIOD OF SIXTY DAYS (BEGINNING SEPTEMBER 18,2005). A FINE IN THE AMOUNT OF $5000. THE FINE SHALL BE DUE AND PAYABLE EITHER IMMEDIATELY UPON REASSOCIATION WITH A MEMBER FIRM, FOLLOWING THE SIXTY-DAY SUSPENSION NOTED ABOVE, OR PRIOR TO ANY APPLICATION OR REQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDING, WHICHEVER IS EARLIER." Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT - NASD FOUND RESPONDENT IN VIOLATION OF RULE 2110 FOR NOTIFYING THE NASD AND SEC OF POTENTIAL NASD VIOLATIONS BY RECEIVING ADVISOR AFTER LIQUIDATION OF A LONG HELD PORTFOLIO OF MUNICIPAL BONDS AND PRIOR LIQUIDATION OF RECENTLY DECEASED HUSBAND'S PENSION PORTFOLIO INTO LIFE INSURANCE FOR CHILDREN AS BENEFICIARY. DECEASED CLIENT WAS A CLIENT OF RESPONDENT FOR 21 YEARS. RESPONDENT DID NOT PROPERLY DISCLOSE HER IDENTIY WHEN SHE NOTIFIED THE SRO'S OF POTENTIAL QUESTIONABLE ACTIVITY