Cynthia Lynn Davenport (CRD # 2484400, Registered Principal, Norwood, Ohio) submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $20,000, $5,000 of which was jointly and severally with Davenport. Davenport was also suspended from association with any FINRA member in any capacity for two months. Without admitting or denying the findings, the firm and Davenport consented to the described sanctions and to the entry of findings that the firm, acting through Davenport and other individuals, failed to obtain written consent to conduct Web CRD searches pertaining to individuals not seeking registration or assignment with the firm, and falsely certified that written consent had been obtained from the individuals whose CRD records were searched. The findings stated that the firm failed to establish and maintain adequate written procedures to supervise the use of Web CRD, and failed to adequately train and supervise all of the employees who were permitted access to Web CRD to ensure that the requisite written consents were obtained prior to conducting all Web CRD searches.

The suspension is in effect from January 5, 2009, through March 4, 2009. (FINRA Case # 2007007333001)