Independence Square Holdings, Llc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, BATANSKY CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED IN A PRIVATE SECURITIES TRANSACTION BY FACILITATING A $50,000 INVESTMENT BY HIS SON, IN A CONVERTIBLE PROMISSORY NOTE, WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. THE FINDINGS STATED THAT BATANSKY FORWARDED HIS SON, A FIRM CUSTOMER, AN EMAIL CONCERNING AN INVESTMENT OPPORTUNITY IN A PRIVATELY HELD MEDICAL DEVICE COMPANY. ATTACHED TO THE EMAIL WAS AN INVESTOR OVERVIEW, CONVERTIBLE NOTE TERM SHEET AND A SUBSCRIPTION AGREEMENT. USING HIS PERSONAL EMAIL ACCOUNT, BATANSKY SENT THE COMPANY'S PLACEMENT AGENT HIS SON'S RESIDENTIAL ADDRESS AND DATE OF BIRTH. BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO INFORM THE PLACEMENT AGENT THAT HIS SON "WILL DO $50,000 OF THE COMPANY." BATANSKY ASKED HIS SALES ASSISTANT TO EMAIL THE PLACEMENT AGENT A SCANNED COPY OF HIS SON'S SIGNED SUBSCRIPTION AGREEMENT FOR HIS $50,000 INVESTMENT, A COMPLETED INVESTOR PROFILE AND QUESTIONNAIRE, AND A W-9 TAX FORM. BATANSKY THEREAFTER ARRANGED THROUGH HIS BRANCH OFFICE'S OPERATIONS DEPARTMENT TO WIRE $50,000 FROM HIS SON'S BROKERAGE ACCOUNT TO HIS PERSONAL BANK ACCOUNT. BATANSKY PREPARED AND EMAILED HIS SON A DRAFT LETTER OF INSTRUCTION TO HIS BANK TO WIRE $50,000 FROM HIS ACCOUNT TO THE COMPANY'S BANK ACCOUNT. BATANSKY'S SON COMPLETED HIS $50,000 INVESTMENT IN THE COMPANY. BATANSKY DID NOT RECEIVE ANY COMPENSATION IN CONNECTION WITH HIS SON'S INVESTMENT. BATANSKY FALSELY ATTESTED IN A COMPLIANCE QUESTIONNAIRE THAT HE HAD NOT PARTICIPATED IN ANY PRIVATE SECURITIES TRANSACTIONS. THE FINDINGS ALSO STATED THAT BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO SEND A TOTAL OF 32 SECURITIES-RELATED EMAILS THAT WERE NOT MONITORED OR RETAINED BY THE FIRM. BATANSKY ATTESTED IN COMPLIANCE QUESTIONNAIRES THAT HE UNDERSTOOD THAT HE MUST USE FIRM OR APPROVED EMAIL ADDRESSES FOR ALL BUSINESS-RELATED COMMUNICATIONS WITH ALL CLIENTS AND PROSPECTS. Status: Final Sanction Detail: 30 DAY SUSPENSION FOR ALL CAPACITIES. FINES AND PENALTIES TOTALING $7,500.00 Summary: ACCEPTANCE, WAIVER AND CONSENT WAS ENTERED INTO AS A FINAL ORDER. THIS INVOLVED A 30 DAY SUSPENSION, PENALTIES, AND FINES. THIS HAS SENSE BEEN SATISFIED, SUSPENSION WAS SERVED 11/16/2020 - 12/15/2020.