SEC Division of Trading and Markets (non)-No-Action Letter: Ownership of BD by Suspended Person

Request for No-Action Letter was submitted to enable Jeffrey A. Wolfson to maintain his capital in Sallerson, a registered broker-dealer of which Wolfson owned approximately 70%, even though Wolfson was subject to a bar against being associated with a broker-dealer for a one-year period. Wolfson had proposed to put his ownership interest in a blind trust. Although the Division did not grant the letter, the denial of the grant was only to the point that putting Wolfson's stock in a blind trust was not sufficient to demonstrate that Wolfson would not be associated with the broker-dealer going forward. That is, Wolfson was NOT required to sell his ownership interest. Rather, the (non) no-action letter effectively warned Wolfson that if he engaged in activities during the year involving him with the broker-dealer that Wolfson would be deemed to have violated the terms of this sanction.

Cross-Reference(s): Exchange Act Sections 3(a)(18), 15(b)(6), 21C.

View letter in full here (links externally to SEC website).