James Richard Willard III (CRD # 1212281, Registered Principal, Greene, New York) was fined $92,500 and suspended from association with any FINRA member in any capacity for two years. The fine is due and payable upon Willard’s return to the securities industry. The sanctions were based on findings that Willard made an unsuitable recommendation to a customer without having a reasonable basis for believing that the recommendation was suitable based on the customer’s age, investment objectives, risk tolerance, financial situation and needs. The findings stated that, in connection with the unsuitable transaction, Willard created false documents that caused his member firm’s books and records to contain false and misleading information regarding the customer’s age. The findings also stated that Willard willfully reported false information and willfully failed to disclose material information on his Forms U4.
The suspension is in effect from February 16, 2010, through February 15, 2012.

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