The Blakeley Group, Inc.

Allegations: RESPONDENT EFFECTED 24 TRANSACTIONS IN TEN OF HIS CUSTOMERS' ACCOUNTS. RESPONDENT DID NOT SPEAK WITH ANY OF THESE CUSTOMERS TO RECEIVE AUTHORIZATION FROM ANY OF THEM TO BUY OR SELL THESE SECURITIES IN EACH OF THEIR ACCOUNTS BEFORE HE MADE EACH OF THE TRANSACTIONS. RESPONDENT EFFECTED EACH OF THE TRANSACTIONS ON A DISCRETIONARY BASIS IN ACCOUTS THAT WERE DESIGNATED AS NON DISCRETIONARY ACCOUNTS BY THE FIRM. Status: Final Sanction Detail: A SUSPENSION FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 15 BUSINESS DAYS. Summary: RESPONDENT WORKED CLOSELY WITH THE CUSTOMERS WHOSE MONEY CONSTITUTED THE PORTFOLIOS AND CONSULTED WITH THEM FREQUENTLY WITH REGARD TO THEIR INVESTMENTS AND FINANCIAL POSITIONS. RESPONDENT'S CLIENTS WERE SOPHISTICATED, BUSY AND TRAVELED EXTENSIVELY WHICH LEFT THEM LITTLE TIME TO TAKE CALLS DURING THE WORK WEEK. THE CUSTOMERS WERE HAPPY KNOWING THAT RESPONDENT AND THE GROUP THAT HE HEADED AT SMITH BARNEY (THE BLAKELEY GROUP) WERE WORKING ON THE CUSTOMERS' BEHALF. DURING MEETINGS WITH CUSTOMERS RESPONDENT RECEIVED VERBAL PERMISSION FROM CUSTOMERS TO ENTER TRADES ON THEIR BEHALF WITH THE UNDERSTANDING THAT ONE OF THE MEMBERS OF THE BLAKELEY GROUP WOULD CALL AND DISCUSS THE TRADES WITH THE CUSTOMERS. UNFORTUNATELY, IT APPEARED THAT, ON THE TWO DAYS IN QUESTION, THE CUSTOMERS WERE NOT CONTACTED IN ADVANCE OF THE TRADES. THIS WAS AN ISOLATED OCCURRENCE THAT WOULD NOT BE REPEATED.