American Wealth Management, Inc.

American Wealth Management, Inc. (CRD #25536, Atlanta, Georgia) and Jerome August Borzello (CRD #801913, Registered Principal, Dunwoody, Georgia) submitted a Letter of Acceptance, Waiver and Consent in which they were censured and fined $15,000, jointly and severally. The firm must also pay $6,284.09 in disgorgement of excess commissions, plus interest, to public customers. Without admitting or denying the findings, the firm and Borzello consented to the described sanctions and to the entry of findings that the firm, acting through Borzello, conducted a securities business while failing to maintain its minimum net capital as Section 15(c) of the Securities and Exchange Act of 1934 requires. The findings stated that the firm, acting through Borzello, prepared an inaccurate general ledger, trial balance and net capital computation for a period of time. The findings also stated that the firm, acting through Borzello, failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to supervise the activities of each registered representative associated with the firm to review and monitor commissions for fairness; to adequately report customer complaints; review, approve and maintain internal communications; report transactions in Trade Reporting and Compliance Engine (TRACE) eligible securities to the TRACE reporting system in a timely manner; and impose heightened supervision and monitor representatives put on heightened supervision. The findings also included that the firm’s written supervisory procedures were not reasonably designed to adequately address mutual fund sales and did not adequately address municipal securities sales activities. NASD found that the firm failed to enforce its supervisory procedures in that it failed to conduct annual inspections of its non-branch office locations and failed to complete questionnaires for branch office inspections as its written supervisory procedures required. (NASD Case #E072004002501)

 
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