G.C. Andersen Partners Capital, LLC (CRD # 44631, New York, New York) and Bruce Neal Orr (CRD # 1708096, Registered Principal, St. Augustine, Florida) submitted Letters of Acceptance, Waiver and Consent in which the firm was censured and fined $65,000, and Orr was censured and fined $15,000. Without admitting or denying the findings, the firm and Orr consented to the described sanctions and to the entry of findings that the firm, acting through Orr, participated in private placements that were contingent upon receiving a minimum and/or a maximum of investor funds and during the offering periods, the firm failed to transmit investor funds to a bank that had agreed, in writing, to hold such funds in escrow for the investors until the offering contingency was met but, instead, investor funds were held in an account over which Orr had control as escrow agent. The findings stated that, as a result of the firm’s control over the funds held in connection with the private placements, it was deemed to be in control of customer funds, which resulted in an increase in its net capital requirement, but the firm was found to be deficient in its net capital while conducting a securities business. The findings also stated that Orr, on the firm’s behalf, failed to maintain a Cash/Checks Received and Forwarded Blotter, or an equivalent record to reflect the receipt and/or forwarding of funds as required by SEC Rule 17a-3. The findings also included that the firm did not have an adequate email retention system and therefore failed to adequately preserve emails as required. FINRA found that the firm failed to establish and maintain a supervisory system reasonably designed to ensure compliance with applicable laws, rules and regulations in connection with the private placements conducted by the firm, and the firm failed to retain a written record of the dates upon which reviews and branch office inspections were conducted. (FINRA Cases # 2007007256801/# 2007007256802)