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Grassroots Movement to Revise FINRA Fine and Suspension of Richard Botkin

July 25, 2017

Today's article updates the BrokeAndBroker.com Blog's ongoing coverage of the plight of Richard S. Botkin, a 15-year Marine Corps veteran and a registered representative since 1986. "UPDATE: FINRA Rides The Thunder In Vietnam Movie Case" (BrokeAndBroker.com Blog, July 7, 2017). If you are familiar with the background story, CLICK HERE to go directly to today's updated material.


As previously reported, the Financial Industry Regulatory Authority ("FINRA") entered into an Acceptance, Waiver and Consent settlement ("AWC") with Respondent Richard S. Botkin whereby he was fined $15,000 and suspended for four months. In the scheme of things, the fine isn't that much of a sum and the suspension is of a somewhat modest duration. In the scheme of things, Botkin is a little guy on Wall Street. As such, FINRA's AWC with Botkin comes off as a mundane, industry fender-bender . . . except . . . you know, that's largely the problem with the regulation of Wall Street: everything tends to get reduced to numbers. All of which encourages large financial services companies to do a cost-benefits analysis before they opt to rig the markets or sell toxic products. This ennui permeates not only the industry but also those who regulate it.

Wall Street's little guys suspect that the  industry's regulators set up speed traps and engage in nothing more than "gotcha" regulation for the purpose of generating revenue to pay their salaries. That may well be an exaggeration fueled by a healthy dose of paranoia. It may also be the inherent tension within any regulated industry. Unfortunately, when it comes to Wall Street's small fry, their suspicions of unfair regulation take on the hue of truth when we read about the industry's big boys getting non-prosecution agreements, being allowed to hire outside consultants in lieu of having their doors shut, and getting hit with fines that are paid from the pockets of public shareholders and not the responsible executives. And nothing pours more fuel on that fire of distrust than when a regulator pronounces take-it-or-leave-it terms of settlement when negotiating with respondents/defendants that are smaller firms or who are individual men and women, but the press is filled with stories about how respondents/defendants that are large firms or those firms' senior executives had extracted all sorts of concessions from those same regulators for far more serious misconduct.

So what happens to the hundreds of thousands of registered men and women when they drive with a broken taillight on Wall Street? They get pulled over. As they should. What happens next is the problem. On the side of the road, they find themselves in an intimidating setting with several FINRA lawyers, examiners, and investigators and are presented with the choice of bankruptcy by way of pursuing a hearing or career suicide by way of settlement. Talk about a choice of poison. I'm not suggesting, even remotely, that Wall Street's regulators always act without justification. More often than not, the respondents in their cross-hairs are guilty. I concede that point. A broken taillight is a danger, regardless of whether you knew about it. The thing is that some drivers get let off with a warning and an admonition to get it fixed immediately. Other drivers find themselves hauled before a small-town magistrate who doesn't quite like out-of-towners and whose ruling is "pay a $1,000 fine or one-week in jail." Sure, go ahead, call a lawyer. See how well you fare by the time the town magistrate schedules a hearing and subsequently rules against you. Also, there's the matter of the impound fee charged by the judge's nephew at the auto repair shop and the bill for the court costs that will be presented to you by the judge's son-in-law, who happens to be the town's lawyer. Ya wanna appeal that through the state court system? How much justice can you afford?

As I often note, it's just as expensive to defend an innocent client as a guilty one. Does it make sense to incur $40,000 in defense costs when you can settle with FINRA for $5,000? Before you answer that question, factor in that you have a mortgage to pay, a daughter getting married in two months, and a daughter starting her Ivy League college in September. Then ask yourself: Is it worth an additional $35,000 to fight this bull-shit charge or should I just eat the $5,000 fine and get on with my life?

To those who misunderstand my comments, let me take the time, here and now, to dispel any erroneous inferences. There are far too many scamsters and fraudsters in the securities industry. There are far too many FINRA member firms that have no purpose other than to rip-off investors. The bulk of those in regulation serve with distinction and ethics. It is important that there be a credible regulatory oversight of Wall Street, and the most effective arrows in that quiver are fines, suspensions, and bars. Is my position clear enough for you?

What you may be struggling with is my advocacy for "fairness" when it comes to sanctioning weaker and more vulnerable industry respondents. In order to understand where I'm coming from, keep in mind that I am a former industry regulator and a former Hearing Officer for the City of New York. Also, I am a former in-house industry lawyer and a former Series 7/63 registered rep. Another factor that prompts my advocacy is that I was the third generation of my family in the wine and liquor industry before becoming a lawyer -- there is hardly a more regulated business than the one I came from! I have represented the industry in private practice. I have represented public customers in private practice. I have represented witnesses before Congress and have represented industry whistleblowers. In a sense, I have sat at all sides of the table. I have felt the pain and wielded the power. That gives me a very unique perspective.

Consequently, I am convinced that it matters, it matters a great deal, that regulation be a partnership between the regulated and the regulator. It is equally important that we recognize the difference between, on the one hand, unrepentant miscreants who delight in violating the rules and feel no remorse when harming their victims, and, on the other hand, men and women who are inherently decent folks but who violate (sometimes inadvertently and sometimes foolishly) the rules and regulations of the industry. We don't need to excuse their mistakes. We simply need to place things in perspective and bring our humanity to work in order to ensure that the punishment fits the crime.

I have taken up the cause of Richard S. Botkin. Based upon my review of Botkin's FINRA AWC settlement, it appears that he deserved to be sanctioned for his misconduct. Botkin did not deserve, however, to be fined $15,000 and suspended for four months.  Said sanctions are excessive and unwarranted and should be reduced to fairer dimensions. I speak for Richard Botkin because no one else has and, frankly, no one else seems to care. The lack of response from many of the good folks in the industry and in regulation who I contacted to right this wrong has been disheartening.

I am used to being a lone voice in the wilderness. The lack of a supporting chorus is a testament to the regulated's fear of retaliation by their regulators. If my career has been oriented towards changing one thing on Wall Street, it is to replace the "fear" of regulators with "respect." The windmills stand before me. I persist in tilting at them. Thankfully, this time I am joined in battle by Stephen A. Kohn, read: "FINRA 2017 Small Firm Governor Election Underway" (BrokeAndBroker.com Blog, July 24, 2017).


The 2017 Botkin AWC


As alleged by the Financial Industry Regulatory Authority, In the Matter of Richard S. Botkin, Respondent (FINRA AWC 2015045890001, June 30, 2017), Respondent Botkin had received authorization from his former employer Morgan Stanley to engage in an outside business activity ("OBA") involving his participation in a production company designed to create a documentary film. The AWC asserts that in January 2013, Botkin began selling shares in the production company.  Among his share sales, which extended to August 2014, were $170,000 worth to four Morgan Stanley customers and another $75,000 worth of shares to two non-customers. Pointedly, the AWC asserts that:


Botkin participated in the customers' and non-customers' investments in the production company by advertising the production company to potential investors; communicating with investors about their investments; receiving investment checks from the investors and depositing them into the production company's bank account; sending subscription agreements and suitability questionnaires to each investor, who then mailed signed copies back to Botkin; and, as one of only two managing members, running the production company.

At some point, Morgan Stanley apparently deemed Botkin's sales to constitute his engaging in a private securities transaction ("PST"), which the firm prohibited absent the registered person providing prior written notice of the contemplated transactions and obtaining the firm's prior approval. The AWC asserts that Botkin did not follow his firm's PST protocol.
The AWC further asserts that in 2013 and 2014, Botkin provided false answers in response to the firm's annual compliance attestations regarding his PST activities. The production company did produce a film in 2015.

FINRA deemed Botkin's conduct to constitute a violation of NASD Rule 3040 and FINRA Rule 2010. In accordance with the terms of the AWC, FINRA imposed upon Botkin a $15,000 fine and a four-month suspension.

The Measure of a Man

In attempting to discern the character of Respondent Botkin and the proper context for his alleged PST, consider this information posted on the Allegiant Giving  Corporation's (a 501(c)(3) nonprofit organization) website's "Our Team" page:

VETERAN MENTORING PROGRAM

A former Marine Corps infantry officer (active service with 2nd Battalion, 7th Marines and 1st Reconnaissance Battalion), Richard Botkin served 15 years of combined active and reserve duty.

Rich and his wife have been married for 32 years and they have two adult sons.   He is also the author of the book "Ride the Thunder-A Vietnam War Story of Honor and Triumph."   The book is currently on the Commandant's Reading List.    

Since 1998 Rich has been involved in annually leading short-term dental / medical missions to Cambodia where they work with Agape International Missions-an organization dedicated to ending the sexual trafficking of young children-and other in-country Christian missionaries to provide basic relief for the poor and hurting of that country.  

In addition to the notion of aiding those who have selflessly served our nation, Botkin subscribes completely to the Allegiant Battle-concept of not just giving assistance to our veterans, but helping them to become the successful, productive members-and business LEADERS-of society they were created to be.   He refers to the old proverb: "Give a man a fish and you feed him for a day.   TEACH a man to fish and you feed him for life."   This idea and model-combining entrepreneurial opportunities with strategic mentoring-brought to the table by Mark Haney, is something which will not only resonate with the veterans we intend to serve, but also the larger American public which will support and bless these efforts.  

The Book and Movie At Issue


Everything Americans know about the end of the Vietnam War is wrong, contends Richard Botkin, former Marine infantry officer and author of the groundbreaking book Ride the Thunder: A Vietnam War Story of Honor and Triumph.

Now the inspiration for a major motion picture of the same name Ride the Thunder reveals the heroic, untold story of how Vietnamese Marines and their US advisers fought valiantly, turning the tide of an unpopular war and actually winning while Americans 8,000 miles away were being fed only one version of the story.

Focusing on three Marine heroes Colonel John W. Ripley, USMC, Lieutenant Colonel Gerald Turley, USMC and Vietnamese Lieutenant Colonel Le Ba Binh Botkin tells the real history of the Vietnam War with the grainiest of detail he captured through scores of interviews and thousands of hours of tireless research in Vietnam, Cambodia and the US. Highly readable and thoroughly researched, Ride the Thunder profiles numerous American and Vietnamese warriors who sacrificed themselves and their families in the pursuit of freedom. Many paid the ultimate price in the effort to keep their country free of communism.

Reporters would fly into the combat base just long enough to film Marines being shelled and ducking for cover before flying out again to safe areas. Focusing only on dying US soldiers, the American media refused to cover the atrocities committed by the Communists against their own people. Despite these horrors and the fact that the South Vietnamese were fighting desperately for their fledgling democracy the 93rd Congress pulled the plug on all US support and funding.

Even though the American troops were winning on the ground, it was the media and politicians, not warriors, who decided the outcome of the war.


FINRA Sanction Guidelines

According to FINRA's "Sanction Guidelines" under "Selling Away" at pages 14, the "Monetary Sanction" for an "Associated Person" such as Botkin is set forth as a "Fine of $5,000 to $73,000" and the "Suspension, Bar or Other Sanctions" run from 10 business days to a Bar depending upon the dollar amounts of sales. For the dollar amounts sold of "$100,000 to $500,000" a suspension of "3 to 6 months" is offered as a range in the Sanction Guidelines. Among the "Principal Considerations in Determining Sanctions" noted in the Sanction Guidelines are the dollar amount of sales, number of customers, time span of PST, involvement of federal/state/SRO violations, Respondent's perceived benefit from transactions, and respondent's involvement of employer's name in PST, injury to investors, involvement of FINRA member firm customers, extent (if any) of employer's notice of transactions and its instructions/prohibitions (if any) to respondent, and acts of concealment. As alleged in the AWC, Respondent Botkin purportedly sold $170,000 worth to four Morgan Stanley customers and another $75,000 worth of shares to two non-customers.

Readers of the BrokeAndBroker.com Blog know that I detest hypocrisy and, as such, I will not bend the facts to make my opinions more palatable. As I noted in my original coverage of this matter and will reiterate here, the fact that Botkin made a film about the Vietnam War (he was not a Vietnam War veteran but he was a 15-year Marine Corps veteran on active and reserve duty) does not entitle him to a free pass should he violate a compliance policy or regulatory rule; moreover, Respondent Botkin had a prior AWC. Further, his 2017 AWC alleges a PST violation involving sales of $245,000 to six individuals of which four were Morgan Stanley customers. Finally, Respondent Botkin appears to have been represented by a lawyer, who signed off on the AWC, and the terms of the settlement include a waiver of appeal.  

After some 35 years on Wall Street, I have a pretty good feel for what constitutes appropriate sanctions for misconduct. FINRA's imposition of a $15,000 fine and a four-month suspension upon this respondent strikes me as a travesty that serves no true regulatory purpose other than ringing up the cash register.

Stephen Kohn Steps Up

Recently, I announced my support for the candidacy of Stephen Kohn for the 2017 FINRA Small Firm Governor seat on the regulator's Board. I asked Stephen, who serves on FINRA's National Adjudicatory Council, to personally look into this case. I sent copies of my articles about Botkin's fine and suspension to a number of so-called industry dissidents and reform advocates, and also sent the article by email to FINRA. I will not name the names of any recipients. I will note, however, my profound disappointment with the lack of response from folks from whom I had expected better. Sadly, this is a common affliction among FINRA regulatory staff and among industry folks who run for or hold FINRA elective office.

True to his word and consistent with his tireless advocacy of FINRA reform causes, Stephen Kohn informed me that he has fielded several inquiries about Botkin's plight, personally communicated with Botkin and others, and is presently deliberating as to how he might present this matter to FINRA, either in his capacity as a NAC member or consistent with his activities on behalf of the FINRA Small Firm community.  

Hugh Hewitt Says Botkin "Among the Finest Men I Know"

Stephen Kohn sent me a copy of an email he received from Hugh Hewitt, who granted permission for republication here [NOTE: Confidential information redacted by BrokeAndBroker.com Blog]:

-----Original Message-----

From: Hugh [redacted]

Sent: Thursday, July 06, 2017 4:19 PM

To: Stephen [redacted]

Subject: From Hugh Hewitt re Richard Botkin


Dear Mr. Kohn:


I read with interest the article in BrokeandBroker.com by Bill Singer concerning Mr. Botkin. I am a journalist and lawyer, currently host of a nationally syndicated radio talk show, host of an MSNBC weekly television show, Washington Post columnist and partner with the Los Angeles law firm of Larson O'Brien and the author of a dozen books on law, politics and religion. I am a graduate of Harvard College and the University of Michigan Law School, have been confirmed unanimously by the United States Senate to be Deputy Director of the US Office of Personnel Management, served as Assistant Counsel in the White House for President Reagan and as Special Assistant to two Attorneys General as well as having been appointed to two state wide boards in California and serving for 18 years on the Orange County Children and Families Commission. I tell you all this on the chance that it might incline you might take seriously what I have to tell you about Richard Botkin.


He is among the finest men I know. What FINRA did to him was a travesty. A genuine injustice and the consequences of every bad tendency of bureaucracy I have observed over four decades in public service, the law and media. If you spend 30 minutes on the matter you would agree. It shocks my conscience what the government did here and I am not easily shocked. But it's just regulators doing what regulators do: damaging lives while doing no discernible good for anyone and a great deal of harm to Richard's clients of which I am one as are all three of my children. I urge you to follow Bill's advice and investigate. The "investigators" on this matter should at a minimum be disciplined, not Mr. Botkin. Mr. Botkin did not ask me to write this nor do I know if he would approve of me doing so, but Mr. Singer suggested it might save some other innocent victim of this out of control staff down the road, so I write. I am happy to discuss with you at any time


Sincerely,

Hugh Hewitt


Stephen Kohn's Advocacy for Botkin

I have suggested to Stephen Kohn that he seek a review of the AWC by the NAC and/or the FINRA Board. I have also urged Kohn to attempt to persuade FINRA to reduce or eliminate the $15,000 fine or permit Botkin to demonstrate that he has provided a similar monetary value to a veterans group. Also, I have urged Kohn to consider all the attendant facts, with a particular emphasis on the character of Botkin, and to press FINRA to reduce the suspension to no more than three months and preferably one month.  In response, Stephen Kohn indicated that he will consider my suggestions and some ideas of his own and provide me with an update of his efforts on behalf of Richard Botkin.

If you feel strongly about this issue, contact:

Stephen A. Kohn
Stephen A. Kohn & Associates, Ltd.
3232 South Vance Street, Suite 210
Lakewood,  Colorado 80227
303-984-2558
888-984-2558


FROM: Stephen Kohn
Attachments
TO: Bill Singer

Dear Bill:
I am contacting you regarding the BrokeAndBroker.com coverage of the FINRA regulatory settlement involving Richard Botkin, a 15 year U.S. Marine Corp. veteran who was released from Morgan Stanley for an alleged private securities transaction (PST) violation.
In my humble opinion, FINRA Rule 3280, Private Securities Transaction of an Associated Person, is like so many other industry rules that require having a "Law Degree" to really understand its true meaning and the full ramifications attendant to running afoul of it.  As your coverage of Botkin's settlement suggests, he appears to have copped to FINRA's charge and entered into an AWC under some duress and without fully appreciating how sympathetic his case may have been if he had argued for sanctions less than a $15,000 fine and four-month suspension.   Another "feather in the cap" for FINRA enforcement.   I'm guessing that Mr. Botkin accepted a $15,000 fine coupled with a four month suspension rather than going bankrupt. The cost of contesting the charges and pursuing any appeals would have saddled Botkin with a huge legal expense.

Not believing everything I read, I reviewed Mr. Botkin's BrokerCheck, his AWC and read and re-read the BrokeAndBroker.com Blog as well as his "Team" listing on the Allegiant Giving website.   In the interim, I was contacted by Hugh Hewitt by an unsolicited email, which I previously sent to you for your information.  My personal research and communications only amplified my resolve to try to bring this travesty to the attention of top FINRA management.   Being satisfied with whom Mr. Botkin is after only reading about him, I reached out to him to get his take on the issue. He is a sincere guy and quite humble, given his background and accomplishments.  As a veteran industry reform advocate, I recognize that Botkin signed off on a settlement with FINRA in which he admitted to the findings of fact pertaining to his alleged violation of the PST rule. I will not argue that he was wrongly charged or did not engage in the violation.  I will respect the AWC to that extent.  I do not respect the sanctions imposed upon him because they strike me as draconian and excessive to the point of absurdity.  
As a sitting member of the FINRA National Adjudicatory Council ("NAC") I have formally moved to have Mr. Botkin's AWC called for review by the full NAC.
On July 10, 2017, I called the Director of the Appellate Group, described the situation and requested putting Mr. Botkin's AWC on the calendar for review at the next meeting of the NAC.
On July 13, 2017, I made a formal request for review, emailing the Director of the Appellate Group, the Chief Legal Officer of FINRA and the President and CEO of FINRA. I have attached a copy of that email, with redactions of personal information, for your republication.
I quickly received a response from FINRA's Chief Executive Officer that my request will be discussed by the addressees of my email.  
In the meantime, Mr. Botkin has entered his suspension window and I await word from FINRA about a full review of his AWC, fine and suspension.   I am hopeful, but not optimistic that FINRA will suspend his suspension until his AWC is reviewed.
I will keep you apprised of the progress of this important issue.  Please feel free to be in touch.
Stephen


Dear [REDACTED]

On Monday morning, July 10, 2017, you and I spoke of my concern about Richard Botkin, CRD #1571729, and the AWC to which he recently entered into.

I have been reviewing the circumstances of his "violation" and I find, as did "Enforcement" that he was, technically in violation of, I believe, FINRA 3280. (Private Securities Transactions of an Associated Person)

However, I do believe that there is reason to address the penalty meted out and accepted in Mr. Botkin's AWC and call for a review of same before the NAC.

1. Richard Botkin has made the following OBA disclosures:
a. Allegiant Giving. A non-profit geared towards assisting returning military members, members of the Board of Directors, assisting with the functioning of the organization. Disclosed 06/30/13.
b. Ride the Thunder Productions. An LLC formed to promote a movie based on his book about the Vietnam War. Disclosed 11/10/12
c. Author. Non-profit geared towards assisting returning military veterans. Member of the Board of Directors. Hoping to co-author a book about a friend and client that details his life story. Disclosed 06/01/10

2. Having read the AWC, I'm concerned that the fine and suspension imposed on Mr. Botkin is excessive and unwarranted and raises the following questions.
a. Did Mr. Botkin knowingly and intentionally violate 3280?
b. Did Mr. Botkin personally invest in this venture?
c. Did Mr. Botkin personally benefit financially from this movie venture?
d. Have any investors filed any claims or assertions about Mr. Botkin or their support of the production of this movie?

3. I attach an unsolicited email from Hugh Hewitt in support of Mr. Botkin's character.
[REDACTED] being fully aware of the financial and emotional stress inherent in appealing an Enforcement decision, I completely understand Mr. Botkin's entering into an AWC as the path of least resistance to being able to continue his humanitarian work and career path albeit with a four month hiccup.

I am asking for review because I feel the penalties are excessive and keeping with my continued, passionate assertion that the Sanction Guidelines are just that; GUIDELINES and not mandates. I feel the penalties meted out are draconian and considering that there has been no harm to anyone, we should look at them and make an adjustment; reduce his suspension to one month as opposed to three and earmark his "fine" to be a donation to Allegiant Giving to further support its work to combat child sex trafficking, globally. Additionally, this would be viewed as a benevolent gesture to support Mr. Botkin's missionary work, providing dental and medical services to the needy in Cambodia. [

I appreciate your consideration.

Sincerely,

Stephen
A personal message from Bill Singer, Esq.,
publisher of the BrokeAndBroker.com Blog
to the FINRA Small Firm community

VOTE FOR STEPHEN KOHN
for 2017 FINRA Small Firm Governor.

Stephen A. Kohn, President/CEO, Stephen A. Kohn & Associates, Ltd., is one of three nominees for 2017 FINRA Small Firm Governor. All three candidates are decent, sincere, and qualified nominees and the small firm community is lucky to have a choice from among such a field.

In recent weeks, Stephen Kohn has joined me in seeking redress of FINRA's unfair fine and excessive term of suspension of military veteran Richard Botkin, read: "Stephen Kohn and Hugh Hewitt Champion Richard Botkin's FINRA Appeal" (BrokeAndBroker.com Blog, July 14, 2017). It is a testament to Stephen's character that following my report about Botkin's dilemma, he immediately reached out to me and offered his assistance. Moreover, Stephen took the initiative and contacted FINRA to press for reconsideration of Botkin's sanctions. I hope to report back to my readers soon with more developments on this case.

Time and time again, Stephen Kohn steps forward when others hang back. Time and time again, Stephen speaks up when others remain silent. As a founder of the NASD and FINRA Dissident Movement(See, "THE MARKETS; Two Independents Are Elected To Serve on N.A.S.D.'s Board" (New York Times, December 22, 1998), and a 35-year industry veteran, I have tired of candidates for FINRA elective office who talk the talk but won't walk the walk.

Stephen Kohn has demonstrated a persistent and consistent record as an unabashed advocate for industry reform and effective regulation. Stephen seeks election as the 2017 FINRA Small Firm Governor in order to make sure that someone fights for the legitimate needs of FINRA's besieged small firms. I know that following his election as the 2017 FINRA Small Firm Governor, Stephen will advance the cause of industry reform and remain a passionate voice in raising the legitimate grievances of the small firm community.  

I support Stephen Kohn's candidacy for the 2017 FINRA Small Firm Governor and urge all BrokeAndBroker.com Blog readers to press their FINRA Small Firm's Executive Representative to cast a proxy in support of Stephen Kohn's candidacy.

VOTE FOR STEPHEN KOHN
for 2017 FINRA Small Firm Governor

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