Leigh Baldwin & Co., Llc

Allegations: NASD RULES 2110, 3010, 6955(A) - LEIGH BALDWIN & CO., LLC FAILED TO TIMELY REPORT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS); TRANSMITTED EXECUTION REPORTS TO OATS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATED TRADE REPORT IN THE NASD TRADE REPORTING SYSTEM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; AND TRANSMITTED NEW ORDER REPORTS AND RELATED SUBSEQUENT REPORTS WHERE THE TIMESTAMP FOR THE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THE RECEIPT OF THE ORDER, THEREBY PREVENTING THE OATS SYSTEM FROM CREATING AN ACCURATE, TIME-SEQUENCED RECORD FROM THE RECEIPT OF THE ORDER THROUGH ITS RESOLUTION. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING OATS REPORTING. 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 $10,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING OATS REPORTING WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. Summary: WE CLEAR ON A FULLY DISCLOSED BASIS THOUGH OUR CLEARING FIRM. IT IS THEIR RESPONSIBILITY TO REPORT TO OATS ON OUR BEHALF.

Allegations: THE STATE OF ILLINOIS ALLEGED TRANSACTIONS IN CLIENTS ACCOUNTS PRIOR TO BROKER/DEALERS REGISTRATION IN THAT STATE. Status: Final Sanction Detail: AMOUNT OF $500 WAS REIMBURSEMENT FOR INVESTIGATIVE COSTS; $1,039.50 FOR REIMBURSEMENT FOR BROKER/DEALER AND REGISTERED REPRESENTATIVE REGISTRATION FEES. TWO BANK CHECKS WERE ISSUED TO SECRETARY OF STATE - STATE OF ILLINOIS ON SEPT. 17, 1997. Summary: UPON REQUESTING BROKER/DEALER REGISTRATION IN THE STATE OF ILLINOIS, WE DID DISCLOSE BUSINESS WHICH HAD BEEN CONDUCTED PRIOR TO OUR REGISTRATION REQUEST. UPON REVIEW, THE STATE SECURITIES COMMISSION INVESTIGATED THE TRANSACTIONS AND REQUIRED US TO OFFER RECISSION TO ALL PARTIES ON ALL TRANSACTIONS. THIS WAS COMPLETED, PER OUR SETTLEMENT AGREEMENT WITH THE STATE OF ILLINOIS. UPON PAYMENT OF BACK REGISTRATION FEES AND NOTICES OF RECISSION FILED, THE STATE THEN APPROVED OUR APPLICATION. AT THAT TIME WE WERE INSTUCTED BY THE STATE OF ILLINOIS TO AMEND FORM B/D WITH A "YES" IN 7G; THEN WAIT 5 DAYS AND CHANGE TO "NO", AS WE HAD FULLY COMPLIED WITH ALL ASPECTS OF THE SETTLEMENT AGREEMENT.

Allegations: NEW HAMPSHIRE ALLEGES UNLICENSED ACTIVITY PRIOR TO REGISTRATION IN THE STATE. Status: Final Sanction Detail: A SETTLEMENT OF $3,000.00 WAS PAID, AS WELL AS $300.00 BACK REGISTRATION FEES. Summary: OUR ATTYS RESPONSE: I (MR. UNGER) NEGOTIATED THE TERMS OF THE CONSENT AGREEMENT AND IN SO DOING, WAS COGNIZANT OF THE QUESTIONS ON FORM BD. THE AGREEMENT WITH NH CONTAINS NO ORDERS OR FINDINGS. IN RESPONSE TO NH INITIAL PROPOSED SETTLEMENT, I SUBMITTED A COUNTER-PROPOSAL WHICH WAS ACCEPTED BY NH SEC. DIV. THE FINAL AGREEMENT WAS DRAFTED AS TO NOT REQUIRE AFFIRMATIVE ANSWERS ON FORM BD, AND HENCE NOT A REPORTABLE EVENT.

Allegations: STATE OF ALABAMA ALLEGED UNLICENSED ACTIVITY BEYOND TRANSACTIONS DISCLOSED IN THE APPLICATION. A CEASE AND DESIST ORDER WAS ENTERED ON 1/14/99, AND A CONSENT ORDER JUNE 1999. Status: Final Sanction Detail: AN ADMINISTRATIVE ASSESSMENT OF $1,000.00 WAS PAID, AS WELL AS $500.00 TO REIMBURSE INVESTIGATE COSTS. Summary: OF THE ALLEGED 13 TRANSACTIONS, 1 OF WHICH WAS CORRECT AND DISCLOSED, 10 WERE TRANSACTED BY A REGISTERED BROKER/DEALER WHICH PIGGY-BACK CLEARS THROUGH OUR FIRM. IT WAS THE POSITION OF THE STATE OF ALABAMA THAT IT WAS STILL OUR FIRMS RESPONSIBILITY FOR THOSE UNLICENSED TRADES.