Need a Loan?
sba.gif (25753 bytes)
Click here!   


  Chapman Spira & Carson, LLC.

Memo from the Chairman
view.gif (3718 bytes)
Venture Capital
Consulting
Mergers & Aquisitions
Corporate Finance
International Finance
Reorganization & Restructuring
Business Plan Analysis
Flow Analysis
Broker Dealer Analysis
Health Care
securities.gif (3395 bytes)
History and News

Disclosure of Information
Multinationals, The Internet

Links

 

 

brokeranal.gif (25178 bytes)Broker Dealer Analysis

- Continued from page 1

Section 8.1 - OPTION PRINCIPALS

Einstein is the qualified/designated Compliance Registered Options Principal (CROP). 
Thelma Einstein is the Registered Options Principal (ROP) and Senior Registered Options Principal (SROP).  Notification of the firm's ROP, SROP and CROP has been filed with the NASD.

Section 8.2 - QUALIFICATIONS OF REPRESENTATIVES

Any Representatives having taken and passed the Series 7 examination since May, 1977 is qualified for both puts and calls. Any Representative having taken and passed the Series 7 examination prior to April, 1977 will provide proof of having taken an additional examination before engaging in put and call transactions.

Section 8.3 -   OPENING OF OPTION ACCOUNTS

1. No order from a customer will be accepted for an option transaction unless the customer's account has been approved for option trading by the CROP or designated Principal.

2. In approving a customer's account for option trading, due diligence will be exercised to ascertain the essential facts relative to the customer regarding his/her financial situation, investment history,investment objectives, accounts with other brokerage firms, and level of option trading.

3. The background and financial information upon which the customer's account has been approved for option trading shall be sent to the customer within fifteen (15) days after the date of approval for verification, if the information is not contained in the customer's account agreement.

4. The written options agreement shall be obtained from the customer within fifteen (1 5) days after the customer's account has been approved for option trading.

5. All option transaction will be approved by the SROP prior to entry, as designed by the CROP.

6. Before approving an investment partnership account for option trading a written document shall be obtained designating the person or persons authorized to sign each agreement on behalf of the partnership and that such authority specifically includes option trading.

Section 8.4 -     OTHER PROCEDURES

1. All order tickets will be initialed by ROP.

2. A periodic review of accounts having option transactions will be made by the ROP to determine if the Registered Representative is observing the suitability standards applicable to each of his/her customers, relative to recommended option trades.

3. Registered Representatives are prohibited from making unwarranted, exaggerated or false claims with respect to transactions in options.

4. Merrill Goldman Corporation will be responsible for delivery of an options prospectus/applicable booklets at or prior to the time an account is approved by option transactions.

Section 8.5 - SUITABILITY

1. Registered Representatives shall not recommend to any customer an option transaction unless the Representative has reasonable grounds to believe upon the basis of information furnished by the customer and after reasonable inquiring by the Representative that the recommended transaction is not unsuitable for the customer.

2. Registered Representatives shall not recommend to any customer an opening option transaction unless he has reasonable basis for believing that the customer has, at the time of the recommendation, such knowledge and experience in financial matters that he may be capable of evaluating the risk of the recommended transaction and is financially able to bear the risk of the recommended position.

Section 8.6 - MAINTENANCE OF RECORDS

1. A file will be maintained for all options related customer complaints and will contain all necessary information to conduct a thorough investigation of the complaint, regarding the Registered Representative, date the complaint was received and what action was taken (if necessary).

2. The firm will have option prospectus and/or applicable booklets concerning options for walk-in customers.

3. The firm will maintain the appropriate personnel records for option principals.

Section 8.7 -    EXERCISE ASSIGNMENT PROCEDURE

Merrill Goldman Corporation will follow the exercise assignment procedure prescribed by the clearing broker-dealer, which executes the transaction.

Section 8.8 - REGULATION T - OPTIONS

It is important that Registered Representatives become familiar with the basic concepts of Regulation T and Merrill Goldman Corporation's 'house" rules, and that Representatives advise their customers of applicable requirements before they enter into an options transaction.For purpose of Regulation T, exchange traded options have no loan value.  Although such options may be purchased either in a special cash account or in a margin account, full payment must be made within the time required by Regulation T, unless the account has available funds to cover the purchase.Full payment for exchange traded options purchased in a special cash account must be made promptly.

While Regulation T requires deposits of cash or securities to meet commitments for exchange trade options made in a margin account within five business days, R should be noted that settlement by clearing firms and the OCC are on a next-business-day basis.   The firm, thereof, must pay out cash for options purchased on behalf of a customer several days before the required deposit is due pursuant to Regulation T. This potential drain on the firm's cash ran be avoided by requiring a deposit from the customer earlier than the date mandated by Regulation T.

In compliance with amendments to Appendix E Article 111, section 33 of the NASD Rules of Fair Practice regarding uncovered option accounts, Merrill Goldman Corporation has the following policies and practices:

Section 8.9 -    APPROVAL OF UNCOVERED OPTION ACCOUNTS

Section 8.9a
The Compliance Registered Option Principal (CROP) or his/her designate shall carefully review the new account application and other applicable agreements/documentation for items stated in Appendix E 'Interpretation of the Board of Governors.' In general, a customer must have a minimum total net worth of $100,000 to $200,000 with a significant portion being liquid net worth.  In addition to net worth, the CROP or his/her designate shall pay special attention to customer's age, number of dependents, investment objectives, prior investment experience in securities including options, and anticipated amount of funds to be approved for options.

Section 8.9b -

All accounts shall be approved by the CROP or his/her designate prior to the entry of any uncovered option order.

Section 8.9c

The CROP, and in his/her absence the Senior Registered Options Principal (SROP)shall maintain written record of the reason(s) for the exception approval with each new account that is approved for uncovered options which does not meet Merrill Goldman set standards.

Section 8.9d

Merrill Goldman Corporation will impose the highest equity requirements for each account involved in uncovered options as set among its correspondence broker, regulation T, any option exchange, or any other regulatory agency that Merrill Goldman Corporation is subject to.

Section 8.9e -

Merrill Goldman Corporation requires all customers to execute and submit the "Special Statement for Uncovered Option Writers" letter before approving any account for uncovered options.  This document shall be maintained with the customer's new account application.

Section 8.10 - SUPERVISION OF UNCOVERED OPTION ACCOUNTS

Section 8.1Oa All orders marked "sell to open" shall be reviewed prior to entry by the SROP or his/her designate.

Section 8.10b
All uncovered option trades shall be reviewed the day after trade date by the SROP of his/her designate.

Section 8.10c
All uncovered options accounts shall be reviewed monthly by the CROP or his/her designate through review of customer monthly statements.

Section 8.1 1 RISK DISCLOSURE STATEMENTS

Within three days of a principal signing or initialing an account that will transact in options, a Risk Disclosure Statement will be sent to the customer explaining the risks regarding option trading.

SECTION 9 - SALES FORCE SUPERVISION -

It is the goal of Merrill Goldman Corporation in its efforts to supervise its sales force to maintain on average 10 registered representatives (Series 7) to each general securities principal (Series 24).  To accomplish this task, as well as to create and maintain an effective chain of communication and supervision the following will be undertaken.

Section 9.1 - Each Registered Representative with Merrill Goldman Corporation will be physically assigned a principal supervisor.  Within this capacity, the supervisor will maintain communication regarding compliance procedures and company information, as well as answering specific questions from the salespeople they supervise.  Ticket, and Account Information will still be processed by the Branch Wire Operator and assistant manager.  The branch manager, will still be held responsible for the overall supervision and compliance by the registered personnel at any branch office.

Section 9.2 - Due to the liquid nature of many of Merrill Goldman brokers, and the fluctuation as to the number of brokers at a specific branch, some supervisors may have more than 10 brokers while others at other branches may have less than 10 to supervise.  Although these fluctuations will vary month to month Merrill Goldman will strive to maintain on average a ratio of 10 brokers to 1 supervisor.

Section 9.3 - New procedures to aid in the expansion of the firm will include

certain requirements for supervisors (Series 24).

Section 9.3a - All Branch Managers will continue to be supervisors.

Section 9.3b - All Assistant Branch Manager will be supervisors.

Section 9.3c - All school instructors will be supervisors.

Section 9.3d - Any brokers participating in the New Mentor Program will be

supervisors.

It is believed that implementing these new procedures will create a strong communication and supervision link between the supervisors of Cheatem's and Fleecem's sales force.  Continued expansion will include these new procedures as well as the maintenance of the 10 to I ratio. Expansion will not be undertaken until such communication and managerial structures are in place.

Section 9.4 - A physical list of which sales people are supervised by which principals will be required and kept in the home office, by the registered compliance officer, as well as at each branch off ice.

Section 9.5 - Any misbehavior or problems will be referred by the direct supervisor to the branch manager.  The branch manager will then report to the registered compliance officer, who will in turn issue instructions.

APPENDIX I
OPTION STRATEGIES AND CUSTOMER POLICIES
SECTION 1 - FIRM POLICIES -

This section is designed to inform brokers that plan on conducting Option transactions with customers on firm policies and well as suggest guidelines in dealing with customers.It should be noted that although their are various option strategies are available, Merrill Goldman Corporation does not intend to transact in risky or speculative option strategies

Section 1.1 - CLIENT TRADING ACCOUNTS:

To conduct option transactions with Merrill Goldman Corporation the client must have trading account with Fleecem and Howe.

Section 1.2 - CLIENT RECOMMENDATIONS:

It is the responsibility of the Registered Representative to introduce option strategy only that is compatible with the clients stated objectives.  Discussion should be conducted with each client to be sure he/she understands both the potential risk and reward.

Section 1.3 - PERCENTAGE OF TOTAL INVESTMENTS IN OPTIONS

It is the responsibility of the Registered Representative to set a conservative maximum percentage of any clients trading funds to be used for option speculation.

Section 1.4 - OPTION DISCLOSURE DOCUMENT

It is the responsibility of the broker to confirm and/or send option agreement and OCC disclosure document together and to have a signed option agreement on file before any option trades take place.

Section 1.5 - STOCK TRANSACTIONS VERSUS OPTION POSITIONS

Each broker is required to cross check stock transactions with the clients open option positions.

Section 1.6 - SUGGESTED TRANSACTIONS

Merrill Goldman Corporation limits option transactions to:Short Covered calls and short covered spreads.  Alternatively, on the long side the client may purchase calls and/or puts.

Section 1.7 - NAKED OPTIONS

Naked options are not available at Merrill Goldman Corporation.These outlines and suggestions are subject to periodic review by the firms Compliance Registered Options Principal (CROP) and failure to comply with these policies may result in discipline and or termination.For more information or specific questions regarding firm option policies and particular circumstances contact either your branch manager or the firms CROP.

BASIC OPTION STRATEGIES

LONG CALLS
Hedge Position - (Bear Position)
Long Calls, Short Stock (Assume short stock sale & strike price identical)
Purpose: Protection from an upward movement of the underlying stock
Risk Reward
100% of premium Short sales-price minus premium
Speculative Position - (Bull Position)
Long Calls
Purpose: Strictly Speculation
Risk Reward
100% of premium Unlimited

SHORT CALLS -
Neutral Position
Short Calls, Long Stock
Purpose: Generate Revenue
Risk Reward
Opportunity Loss Premium Only
Speculative Position
Short Calls
Naked or Uncovered - NOT AVAILABLE
Use Long Puts as alternative

LONG PUTS -
Hedge Position - (Bull Position)
Long Puts, Long Stock (assume stock cost & strike price are identical
Purpose: Protection an downward movement of stock
Risk Reward
100% of premium Unlimited
Speculative Position - (Bear Position)
Long Puts
Purpose: Strictly Speculative
Risk Reward
100% of premium Strike minus Premium -

SHORT PUTS
Neutral Position
Short Puts, Short Stock (assume short stock sale & strike price identical
Purpose: Generate Revenue
Risk/Reward
100% of premium = Strike minus Premium
Speculative Position - (Bull Position)
Short Puts
Naked or Uncovered - NOT AVAILABLE
Use Long Calls as alternative

APPENDIX 11
FLEECEM AND HOWE SECURITIES CORPORATION
BRANCH OFFICES


339 Wall Street, Suite 948
New York, New York 10294
Telephone: (212) 997-8343
Facsimile: (212)-997-8344

        Dated: November 2, 1998

This manual is to illustrate and give guidelines as to how branch offices are to run, what minimum requirements and criteria are, as well as general descriptions for office personnel.These guidelines are just that.  Branch managers hold the right to alter or adjust these policies or guidelines as long as they do not interfere with the firm's compliance and written supervisory procedures.

SECTION I    BRANCH OFFICE RESPONSIBILITIES

Section 1.1 BRANCH OFFICE HOURS

Merrill Goldman Corporation requires that branch offices be open for business from 9:30 a.m. Eastern Standard Time to 4:00 p.m. Eastern Standard Time.  In general, branch offices should be open later in the evening to allow both full-time and part-time brokers access to branch resources and well as for client meetings.During market hours, a Series 24, dully appointed by the branch manager must be present.

Section 1.2 - SUPERVISION OF REGISTERED PERSONNEL

The branch office is a designated OSJ (Office of Supervisory Jurisdiction) therefore a procedure must be established to maintain a system of supervision.  These policies should be designed to monitor the activities of each registered representative and associated person and therefore try to achieve compliance to applicable securities laws, and firm procedures and policies.

Section 1.3 - NASD MANUAL

Each OSJ must maintain at least two (2) copies of the NASD Manual, and make them readily accessible to associated personnel of Merrill Goldman Corporation.

Section 1.4  MERRILL GOLDMAN SECURITIES CORPORATION -WRITTEN SUPERVISORY PROCEDURES

Each OSJ will be required to maintain at least one edition of the most recent version of the firm's written supervisory procedures.  These WSP's must be accessible to all registered personnel.

Section 1.5 - TRADE TICKETS

All trade tickets must be reviewed by the branch manager at the end of business each day.  A binder should be kept with tickets for each production month.Tickets must be reviewed with at least an initial on the first and last ticket for each trade period.

Section 1.6 -MAIL PROCEDURES

Mail must be opened by a designated person appointed by the branch manager.  Mail must be opened in a secure area and reviewed for any monies, securities, and or letters of complaint.  The mail should then be disseminated to the appropriate personnel.

Section 1.7 - NEW ACCOUNTS

New accounts must be reviewed and approved by the branch manager and/or designated person.  Upon approval, the accounts would be opened in the SIS System.   A new account number will be assigned and the account would then be officially opened.The application must be completed and signed by the branch manager and then forwarded to the corporate offices.  The back (cardboard like) copy should be torn and given to the broker .  It is suggested that copies be made of all customer accounts, W-9's and Margin Agreements before being forwarded to corporate.If the application is not completed correctly, it will be returned to the branch office for correction.

Section 1.8 - PLACING ORDERS

All orders will be placed by the appointed personnel by the branch managers directly to trading.The ticket should be stamped numerically and time stamped.   Upon giving the order it will be read back to confirm.  If this is correct the order will be placed (a drop copy will be printed in the branch office). A comparison to the order and the drop copy should be conducted immediately to confirm that no mistakes have been made.Execution will automatically print in the branch office, at which time the tickets should be appropriately checked and a copy distributed to the broker of record.Foreign stocks, Mutual Funds and Bond orders will receive a telephone execution.

Section 1.9 - REGULATION T EXTENSIONS

If an extension is required for a customer account, a wire will be received explaining the amount due, the customer account, broker number and date of expiration.  A wire must be received back to trading by 4:00 p.m. Eastern Standard Time giving the information to proceed. (i.e. Please Grant an Extension, or Extension is not needed.)If a wire is not received, an extension will automatically be sought and charged to the broker of record.

Section 1.10 - CANCEL & REBILLS

If for some reason an error took, place in a trade a Cancel & Rebill form would be completed and faxed to Trading.  If in 3 days the correction had not been made, daily wires to trading should be done until completed.

Section 1.1 1 -ACCOUNT INSTRUCTIONS

Account instructions should be completed by each broker and forwarded to the appropriate person in each branch office.  These instructions should then either be wired or faxed to corporate.  If the instructions have not been completed in 3 days, daily wires to trading should be done until completed.

Section 1.12 - SELECTNET TRADES

To place a SELECTNET trade each broker should call their assigned trader (by branch office) to instruct and place the trade.  To place the order, a limit, branch and broker number must be received.  If execution occurs, a wire would be sent to the wire operator "stating the shares were bought at the execution price and waiting for ticket".If the execution report does not occur in 10 minutes, it should be assumed that the order did not execute.  It is not the responsibility of the trader to inform the broker that the order did not execute.An order should then be placed by the wire operator to execute a trade "from inventory" indicating that this trade is now completed.  An execution report to the customer account would then follow.

Section 1.13 - MUTUAL FUND TRANSACTIONS

Any mutual fund transaction called into trading will be executed on the next business day.  Telephone execution will be received by the branch office.After execution a mutual fund letter must be completed by the broker of record and either faxed or pouched to corporate.It is suggested that a copy be maintained for branch records.

Section 1.14 - MARGIN AGREEMENTS

Margin Agreements must be completed in full.  Upon completion the document would be forwarded to corporate for correspondent approval.  In general it should take 3 to 4 days for margin approval.  To expedite this process the margin agreement may be faxed for approval.  However, this should be an exception.It is suggested that a copy be maintained for branch records.

Section 1.15 - OPTION AGREEMENTS

Option Agreements must be completed in full.  Upon completion and signed by the broker it should be forwarded to corporate for ROP approval.  In general it should take 7 to 10 days for option approval.  To expedite this process the option agreement may be faxed for approval.  However, this should be an exception.It is possible to utilize the same agreement for Margin & Option approval.

Section 1. 1 6 - IRA APPLICATIONS

Completed IRA Application should be forwarded to corporate.   Any checks for application fees should also be included.It is suggested that a copy be maintained for branch records.

SECTION 2 - TRANSMITTALS AND REPORTS

Merrill Goldman requires full documentation on the transmittal of all paperwork, securities, and monies.  In addition, Merrill Goldman Corporation will provide both the branch and brokers with various reports for their benefit.If for any reason, paperwork, checks, or securities are not reflected in the account in 3 days an immediate call should be made to cashiering to confirm the receipt of the documents and the current status. All documents sent to corporate should be stamped with the branch number in a strong color (such as Red or Green) to ease the processing of paperwork.

Section 2.1 - CASH TRANSMITTALS

To document the sending of checks, a cash transmittal must be completed in full.  This would include, the branch, prepares the customer account number, name and the amount for the check.  Upon completion the pink copy would be kept for branch records, while the original and checks would be pouched to corporate.It is suggested that copies of all checks transmitted be kept until deposited in the customer's account. 

Section 2.2 - SECURITIES TRANSMITTALS

To document the sending of securities, a securities transmittal must be completed in full.  This would include branch, prepares the customers name, account number the security description, CUSIP number, and certificate number.  Upon completion the pink copy would be kept for branch records, while the original and securities would be pouched to corporate.It is suggested that copies of all securities transmitted be kept until deposited in the customer's account. 

Section 2.3 - DOCUMENT TRANSMITTALS

To document the sending of documents, a document transmittal must be completed in full.  This would include branch, prepares the customer name, account number and the document being sent.  Upon completion the pink copy would be kept for branch records, while originals and documents would be pouched to corporate.It is suggested that copies of all paperwork be kept and maintained in a branch account file.

Section 2.4 - MONEYLINE REPORTS

Moneyline reports, per broker are printed every Monday, Wednesday and Friday and pouched out to the branch office.  These reports give a report to the broker on each account with a current position, such as current market value, debits and free cash.Upon receipt of the Moneyline reports, they should be distributed to the appropriate broker.
There is no need to copy or maintain a record on behalf of the branch.

Section 2.5 -   A/E BLOTTERS

A/E Blotters by branch and broker number will be received for brokers with activity.  These reports show the customer and transaction as well as the gross commission generated.These reports upon receipt should be distributed to each broker.   It is suggested that a copy be maintained by the branch manager as an overview for broker activity and business production.

Section 2.6 - WEEKLY REPORTS

Each branch office will receive weekly reports from corporate.   These reports are designed to keep managers informed of brokers and customer accounts.

Section 2.6(a) - BROKER REPORT

Each week a report will be generated showing brokers at each branch office.  This will include work status, (i.e.  full-time or part-time) and broker number.

Section 2.6(b) - PART-TIME MAILING

Brokers that desire to have their information mailed to them bi-weekly will code their file as "part-time".  The branch will receive a weekly report of those brokers coded part-time.  Unless informed otherwise all brokers will be coded part-time,

Section 2.6(c) - CONFIRM LIST

A list will be generated for all brokers that require a confirmation call upon execution of an order.  This list will reflect those brokers that desire a call as well as the designated phone number for contact.Broker files should be coded Y for "Yes on Confirmation", N for "No Confirmation" and D for "Don't Know".  All broker files are D (Don't Know) until notified otherwise.

Section 2.6(d) - DON'T KNOW LIST

This report is generated to reflect those broker files that reflect a D for Don't Know.  This generally indicates that the broker information form has never been received by corporate.

Section 2.7 - CUSTOMER ACCOUNTS

This report shows all customer accounts opened in the Merrill Goldman customer account database.  Sorted by broker number, this report indicates accounts opened.   Should a customer account not reflect on this report, it indicates one of two things.

1 . The account has been opened in the branch in SIS, but the paperwork has not yet been received and entered into the Nosegrabber Account database.

2. There is a problem.  The account has not been input, or the account was opened under the wrong branch number, or was not transferred properly.  A follow up call or wire should be placed to follow up.It is suggested that before action is taken, the branch should wait for another Customer Account Report to see if the problems have been resolved or if the account has since been input.

Section 2.8 - MONTHLY REPORTS

Each branch will also receive reports once a month, informing the branch of various information.

Section 2.8(a) - BROKER STATE REGISTRATION

Once a month reports for all brokers will be Generated reflecting all states that Merrill Goldman currently shows them to be registered in.  Should their be a conflict or problem a call should be placed to trading.

These reports upon receipt should be given to each broker.

Section 2.8(b) - NO NEW BROKER ORIENTATION ATTENDANCE

Merrill Goldman Corporation requires all registered personnel to attend a New Broker Orientation.  On a monthly basis a report will be sent showing all brokers by branch that have not attended a NBO.

Section 2.8(c) - NO ICA AGREEMENT

Merrill Goldman Corporation requires a completed Independent Contractors Agreement. On a monthly basis a report will be sent showing all brokers by branch that have not completed an ICA.

SECTION 3 - DISSEMINATION OF INFORMATION AND BRANCH MEETINGS

Although each branch may differ, the dissemination of information to brokers is vital.  Given the many part-time brokers at Merrill Goldman Corporation this becomes even more crucial.  It is mandatory that branch offices offer certain meetings and information while others are just suggestions.

Section 3.1 - WEEKLY BRANCH MEETING

Each branch should hold a weekly broker meeting to explain firm and branch procedures as well as current projects and business development programs.

Section 3.2 - MONTHLY PART-TIME MEETING

Each branch will be required to hold a part-time broker meeting at least once a month. This meeting should be held in the evening to allow working brokers to attend.  Again branch information procedures and projects should be covered.

Section 3.3 - PART-TIME BROKER MAILINGS

For those brokers files coded part-time a bi-weekly mailing of information will take place. This takes place every second Friday. On Thursday, before the mailing, labels for each part-time broker will be sent to the branch office to facilitate this mailing.

Section 3.4 - CONFIRMATION CALLS

It is vital that part-time brokers receive calls upon order execution if they so desire. To this end, broker files must be coded "Y" for confirmation calls. Should an order execute for such a broker a call should immediately be made to the confirmation number.If that number is not answered, it is NOT the responsibility of the branch to track down the broker.  That number can be changed by the broker should they so desire.

Section 3.5 - BRANCH NEWSLETTERS

It is suggested that a monthly branch newsletter explaining current projects, procedures and meetings be sent out to all part-time brokers.

Section 3.6 - STATE REGISTRATIONS

The branch should inform brokers of all states that Merrill Goldman Corporation is registered and how each broker can register in a state.A monthly report will be received by each branch reflecting states that Merrill Goldman Corporation is registered in.

SECTION 4 - MAINTENANCE OF RECORDS

Each branch is required to maintain certain information relating to customer accounts and brokers.  To this end, the following procedures have been implemented.

Section 4.1 - BROKER INFORMATION SHEETS

Upon a new broker joining a branch, a broker information sheet should be completed giving pertinent information.  A copy of this sheet should be forwarded to corporate to update the computer file on the broker.  The original should be held by the branch and kept current.It should be noted that upon update of the computer file, corporate will discard the information sheet.  Thus, it is important that the original be kept at the office.

Section 4. - ADVERTISING

A separate file of all advertisements should be kept by the branch.   Each advertisement should be initialed and dated by the branch manager.

Section 4.3 - COMPLAINTS

A separate file of all complaints should be kept by the branch.   In the event of a complaint being received please consult the firms Written Supervisory Procedures.

Section 4.4 - CUSTOMER ACCOUNTS

Although all original and official files for customer accounts are kept at corporate, it is strongly suggested that each branch maintain its own files.  These files would hold copies of new account applications, W-9's, margin agreements, etc.,Duplicate 3 x 5 cards will also be sent to the branch.  One should be given to the broker of record.  The other should be held by the branch.As new cards are received, the existing card should be discarded.

SECTION 5 - BRANCH MANAGEMENT & PERSONNEL

Although the staffing of branches may differ, certain procedures and responsibilities will always be present.  The below descriptions explain job function and responsibilities.

Section 5.1 - BRANCH MANAGER

A manager's first responsibility is the overall supervision of all aspects and functions of the office by ensuring that branch operations are in full compliance with all regulatory bodies and MSC Corporate objectives.

Section 5.1(a) - REVIEW OF TRANSACTIONS AND NEW ACCOUNTS

The branch manager is responsible to review all transactions and new accounts.  In the event that the manager does not conduct these functions, an appointed person must be stated.

Section 5.2 - ASSISTANT MANGER

The Assistant Manager is, in essence, the Manager's right hand person.  He/She should at any given time,be able to take over the functions of an office without there being a gap to bridge.  Therefore, the requirements for an Assistant Manager are as rigid as for the Manager.

Section 5.2(a) -COMPLIANCE ASSISTANCE

It is the Assistant Manager's job to be available to do whatever is necessary for the Manager to be sure his office is in total compliance.

Section 5.3 - WIRE OPERATOR

The wire operator is designed to disseminate information to brokers, as well as place and execute orders on behalf of the branch.  To this end, the wire operator must be in the office no later than 9:15 Eastern Standard Time.The wire operator will also be responsible for logging paperwork, checks and securities and pouching them to corporate.  In essence, the wire operator will be the main communication point between the branch and trading.  All telephone conversations and wire communications should be kept private and/or confidential.The wire operator must have a fingerprint card on file at the corporate offices of Merrill Goldman Corporation.

Section 5.3(a) -DISSEMINATION OF INFORMATION

The wire operator will be responsible for disbursing broker reports and information coming from corporate.
Upon execution the trade ticket should be noted and given to the broker of record.  If a part-time broker, a confirmation call should be placed depending on the broker file code.

Section 5.3(b) -NEW ACCOUNTS

The wire operator will also be responsible to open new accounts directly into the SIS system.  Thus they must be familiar with SIS, as well as the necessary paperwork to open a customer account.

Section 5.3(c) - ORDER DESK

The order desk will be kept in a clean and orderly fashion.   The number stamp will be reset every day, as well as accurate date and time on the time stamp.   Tickets shall be kept well stocked as well as a rack for open day and good till cancel orders.

Section 5.4(d) - BRANCH RECORDS AND FILES

It will also be the responsibility of the wire operator to maintain the branch files on brokers and customers.

Section 5.5 - RECEPTIONIST

The main responsibility of the receptionist is to answer incoming telephone calls.  However, the receptionist may be utilized as a support person for the office.All telephone calls must be answered, "Merrill Goldman Corporation".  All messages shall be filed or processed according to branch procedures,

THE REGULATORS

For your convenience we have included a list of State Securities Offices. I you feel that you have a problem with your broker, these may be the people to call.

State Securities Regulators

ALABAMA
RSA Plaza
Alabama Securities Commission
770 Washington Ave., Suite 570
Montgomery, AL 36130-4700
FedEx Zip: 36104
(334) 242-2984 or (800) 222-1253

ALASKA
Division of Banking & Securities
State Office Building
9th Floor
333 Willoughby Avenue
Juneau, AK 99801
Mailing address:
P.O. Box 110807
Juneau, AK 99811-0807
(907) 465-2521

ARIZONA
Arizona Corporation Commission
1300 West Washington St., 3rd Floor
Phoenix, AZ 85007
(602) 542-4242

ARKANSAS
Arkansas Securities Department
Heritage West Building
201 East Markham, 3rd Floor
Little Rock, AR 72201
(501) 324-9260

CALIFORNIA
Department of Corporations
980 9th Street, Suite 500
Sacramento, CA 95814
(916) 445-3062

COLORADO
Division of Securities
1580 Lincoln St., Suite 420
Denver, CO 80203-1506
(303) 894-2320

CONNECTICUT
Department of Banking
260 Constitution Plaza
Hartford, CT 06103-1800
(860) 240-8299

DELAWARE
Delaware Division of Securities
Carvel State Office Building
820 North French St., 8th Floor
Wilmington, DE 19801
(302) 577-8424

DISTRICT OF COLUMBIA
Securities Bureau of the District of Columbia
441 - 4th Street, Suite 870 North
Washington, D.C. 20001
Mailing address:
P.O. Box 37378
Washington, DC 20001
(202) 727-8000 x 30721
(202) 727-3351

FLORIDA
Division of Securities
101 East Gaines Street
Tallahassee, FL 32399-0350
(850) 488-9530

GEORGIA
Securities and Business Regulation Division
802 West Tower, Suite 802
2 Martin Luther King Jr. Dr., SE
Atlanta, GA 30334
(404) 656-3920

HAWAII
Hawaii Corporate & Securities Commission
1010 Richards St., 2nd Floor
Honolulu, HI 96813
Mailing address:
P.O. Box 40
Honolulu, HI 96810
(808) 586-2730

IDAHO
Idaho Securities Bureau
700 West State St., 2nd Floor
Boise, ID 83720
Mailing address:
P.O. Box 83720
Boise, ID 83720-0031
(208) 332-8004

ILLINOIS
Illinois Securities Department
Lincoln Tower
Suite 200
520 South Second St.
Springfield, IL 62701
(217) 782-2256

INDIANA
Securities Division
302 West Washington St.
Room E-111
Indianapolis, IN 46204
(317) 232-6688

IOWA
Securities Division
340 East Maple Street
Des Moines, IA 50319
(515) 281-4441

KANSAS
Kansas Securities Commission
618 S. Kansas Ave., 2nd Floor
Topeka, KS 66603-3804
(785) 296-3307

KENTUCKY
Kentucky Department of Financial Institutions
477 Versailles Rd.
Frankfort, KY 40601
(502) 573-3390

LOUISIANA
Louisiana Securities Commission
3445 N. Causeway, Suite 509
Metairie, LA 70002
(504) 846-6970

MAINE
Maine Securities Division
121 State House Station
Augusta, ME 04333-0121
(207) 624-8551

MARYLAND
Maryland Division of Securities
200 St. Paul Place, 20th Floor
Baltimore, MD 21202-2020
(410) 576-6360

MASSACHUSETTS
Massachusetts Securities Division
John W. McCormack Building
One Ashburton Place, Room 1719
Boston, MA 02108
(617) 727-3548

MICHIGAN
Michigan Corporation & Securities Bureau
6546 Mercantile Way
Lansing, Ml 48910
Mailing address:
P.O. Box 30222
Lansing, MI 48909
(517) 334-6215

MINNESOTA
Department of Commerce
133 East Seventh St., 2nd Floor
St. Paul, MN 55101
(612) 296-2283

MISSISSIPPI
Securities Division
202 N. Congress St.
Suite 601
Jackson, MS 39205
P.O. Box 136
Jackson, MS 39205
(601) 359-6371

MISSOURI
Securities Division
Missouri State Information Center
600 West Main St., 2nd Floor
P.O. Box 1276
Jefferson City, MO 65101
(573) 751-2302

MONTANA
Montana Securities Department
126 North Sanders St., Room 270
Helena, MT 59620
Mailing address:
P. O. Box 4009
Helena, MT 59604-4009
(406) 444-2040

NEBRASKA
Nebraska Securities Bureau
Department of Banking & Finance
1200 North St., Suite 311
Lincoln, NE 68508
Mailing address:
P.O. Box 95006
Lincoln, NE 68509-5006
(402) 471-3445

NEVADA
Nevada Securities
555 E. Washington Ave., Suite 5200
Las Vegas, NV 89101
(702) 486-2440

NEW HAMPSHIRE
Bureau of Securities Regulation
State House, Room 204
107 North Main St.
Concord, NH 03301-4989
(603) 271-1463

NEW JERSEY
Bureau of Securities
Gibraltar Building
153 Halsey St., 6th Floor
Newark, NJ 07102
Mailing address:
P.O. Box 47029
Newark, NJ 07101
(973) 504-3600

NEW MEXICO
New Mexico Securities Division
725 St. Michaels Dr.
Sante Fe, NM 87505-7605
Mailing address:
P.O. Box 25101
Santa Fe, NM 87501
(505) 827-7140

NEW YORK
New York Bureau of Investment
Protection and Securities
120 Broadway
23rd Floor
New York, NY 10271
(212) 416-8222

NORTH CAROLINA
North Carolina Securities Division
300 North Salisbury St., Room 302
Raleigh, NC 27603-5909
(919) 733-3924

NORTH DAKOTA
North Dakota Securities Commissioners' Office
State Capitol Building, 5th Floor
600 East Boulevard Ave.
Bismarck, ND 58505-0510
(701) 328-2910

OHIO
Ohio Division of Securities
77 South High St., 22nd Floor
Columbus, OH 43215
(614) 644-7465

OKLAHOMA
Oklahoma Department of Securities
First National Center
120 North Robinson, Suite 860
Oklahoma City, OK 73102
(405) 280-7700

OREGON
Oregon Securities Commission
Department of Insurance & Finance
21 Labor & Industries Building
Salem, OR 93710
(503) 378-4387

PENNSYLVANIA
Pennsylvania Securities Commission
Eastgate Office Building
1010 N. 7th St., 2nd Floor
Harrisburg, PA 17102-1410
(717) 787-5675

PUERTO RICO
Commissioner of Financial Institutions
Centro Europa Building
1492 Ponce De Leon Ave., Suite 600
San Juan, PR 00907-4127
(787) 723-3131

RHODE ISLAND
Department of Business Regulation
233 Richmond St., Suite 232
Providence, Rl 02903-4232
(401) 277-3048

SOUTH CAROLINA
Office of the Attorney General
Securities Section
Rembert C. Dennis Office Building
1000 Assembly St.
Columbia, SC 29202
Mailing address:
P.O Box 11549
Columbia, SC 29211-1549
(803) 734-9916

SOUTH DAKOTA
Division of Securities
118 W. Capitol Ave.
Pierre, SD 57501-2017
(605) 773-4013

TENNESSEE
Tennessee Securities Division
Volunteer Plaza, Suite 680
500 James Robertson Parkway, Suite 680
Nashville, TN 37243-0583
(615) 741-5905

TEXAS
State Securities Board
200 East 10th St., 5th Floor
Austin, TX 78701
Mailing address:
P.O. Box 13167
Austin, TX 78711-3167
(512) 305-8300

UTAH
Securities Division
Herber M. Wells Building
160 East 300 South, 2nd Floor
Salt Lake City, UT 84111
Mailing address:
P.O. Box 146760
Salt Lake City, UT 84114-6760
(801) 530-6600

VERMONT
Department of Banking, Insurance, Securities &
Health Care Administration
Securities Division
89 Main St., Drawer 20
Montpelier, VT 05620-3101
FedEx/Courier:
89 Main Street, 2nd Floor
Montpelier, VT 05620
(802) 828-3301

VIRGINIA
Virginia Division of Securities
1300 E. Main Street
Richmond, VA 23209
Mailing Address:
P.O. Box 1197
Richmond, VA 23218
(804) 371-9051

WASHINGTON
Department of Financial Institutions
Securities Division
General Administration Building
210 11th Avenue, SW
3rd Floor West, Room 300
Olympia, WA 98504
Mailing address:
P.O. Box 9033
Olympia, WA 98507-9033
(360) 902-8760

WEST VIRGINIA
West Virginia Securities Division
State Capitol Building
1900 Kanawha Blvd., East
Room 118 West
Charleston, WV 25305
(304) 558-2257/2258

WISCONSIN
Division of Securities
345 W. Washington Ave.
Madison, Wl 53703
Mailing address:
P.O. Box 1768
Madison, WI 53701-1768
(608) 266-3431

WYOMING
Securities Division
Secretary of State
24th Street & State Capitol Avenue
Cheyenne, WY 82002-0020
(307) 777-7370

We are available for a consultation at your convenience.  If you have read all of the above you are now not only the smartest person on your block but you are also ready to take the registered-rep exam. Welcome to Wall Street!

Well, it turns out that your broker lost all of your money but didn't violate any of the "Blue Sky Regulations" (State Securities Laws)and you are still burning mad. There must be something that you can do. Well this might just be it!

SECURITIES AND EXCHANGE COMMISSION

(If you have a complaint or question about your investments)

Electronic mail:
help@sec.gov

This mailbox may be used to contact the SEC's Office of Investor Education and Assistance. While we encourage inquiries from the public via Internet e-mail, remember that your e-mail is not confidential, and others may intercept and read your e-mail. If you are comfortable in doing so, we ask that you provide your name, postal address, e-mail address, and a daytime telephone number where you can be reached easily. We will make every effort to respond to your inquiry quickly and completely by e-mail, telephone, or letter.

If you have a complaint about your broker or an unfair

sales practice, you may want to preserve the

confidentiality of your communication by sending us a

written letter. We discourage sending your account

numbers and account statements to us via e- mail.

Please address your letter to:

Office of Investor Education and Assistance,
Securities and Exchange Commission,
450 Fifth Street,
N.W., Washington, D.C. 20549.

Fax: 202-942-9634
Telephone: 202-942-7040

Mail:
Office of Investor Education and Assistance
U.S. Securities and Exchange Commission
Mail Stop 2-13
450 Fifth Street, N.W.
Washington, DC 20549
 

We are available for a consultation at your convenience.  If you have read all of the above you are now not only the smartest person on your block but you are also ready to take the registered rep exam. Welcome to Wall Street!

Back | Forward

 

 

 

 

Home | About Us! | Search Us! | Contact Us! | Contents

Copyrighted Worldwide 2002 Chapman Spira & Carson, LLC.
110 Wall Street, 15th Floor. New York, New York 10005
Tel: 212.425.6100 - Fax: 212.425.6229