FINRA

FINRA RULE 2010: PURSUANT TO SEC RULE 15C3-1, LENART'S MEMBER FIRM'S MINIMUM NET CAPITAL REQUIREMENT WAS THE GREATER OF $100,000 OR 6 2/3% OF THE FIRM'S AGGREGATE INDEBTEDNESS AT ALL RELEVANT TIMES. LENART CAUSED HIS FIRM TO FAIL TO MAINTAIN THE MINIMUM NET CAPITAL AS REQUIRED BY SEC RULE 15C3-1. LENART CAUSED HIS FIRM'S NET CAPITAL VIOLATIONS PRIMARILY BY 1) INCLUDING THE PROCEEDS OF A WIRE TRANSFER THAT WERE NOT RECEIVED UNTIL AFTER THE MONTH END; 2) FAILING TO ACCRUE LIABILITIES; 3) INCLUDING FEE RECEIVABLES THAT HAD NO OFFSETTING PAYABLE OR THAT WERE EARNED MORE THAN 60 DAYS PRIOR TO THE MONTH END; 4) INCLUDING THE VALUE OF TRANSFERRED EQUITY SHARES THAT WERE NOT POSTED TO THE FIRM'S ACCOUNT UNTIL AFTER THE MONTH END. LENART ALSO CAUSED HIS FIRM TO VIOLATE SEC RULE 17A-3 BY OVERSTATING NET CAPITAL FOR THE MONTHS OF OCTOBER 30, 2009, DECEMBER 31, 2009, AND JANUARY 29, 2010 BY $996,888, $256,836, AND $853,491, RESPECTIVELY, AND VIOLATE SEC RULE 17A-5 BY FILING INACCURATE FOCUS REPORTS REFLECTING THE OVERSTATED NET CAPITAL FOR THOSE PERIODS. FINALLY, LENART PERMITTED THE FIRM TO VIOLATE SEC RULE 17A-3 BY PREPARING INACCURATE GENERAL LEDGERS FOR THE PERIODS ENDING OCTOBER 30, 2009 AND DECEMBER 31, 2009.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$5,000.00

Suspension

FINANCIAL AND OPERATIONS PRINCIPAL (FINOP)

10 BUSINESS DAYS

4/18/2011

5/2/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, LENART CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN THE CAPACITY OF A FINANCIAL AND OPERATIONS PRINCIPAL (FINOP) FOR 10 BUSINESS DAYS. THE SUSPENSION IS IN EFFECT APRIL 18, 2011 THROUGH MAY 2, 2011. FINE PAID IN FULL JANUARY 10, 2012.

WITHOUT ADMITTING OR DENYING THE FINDING, LENART CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN THE CAPACITY OF A FINANCIAL AND OPERATIONS PRINCIPAL (FINOP) FOR 10 BUSINESS DAYS. THE SUSPENSION IS IN EFFECT APRIL 18, 2011 THROUGH MAY 2, 2011.