Andrew Shubert (CRD # 1457528, Registered Principal, Woodmere, New York) submitted a Letter of Acceptance, Waiver and Consent in which he was censured and fined $10,000. Without admitting or denying the findings, Shubert consented to the described sanctions and to the entry of findings that he failed to establish and maintain written procedures to supervise his member firm’s business consulting services to issuers, including procedures that required a principal to approve the business consulting agreements or to review or supervise the services the firm provided to issuers. The findings stated that, as a result of Schubert’s failing to establish and maintain written procedures, his member firm failed to detect or prevent market making violations.