NEW JERSEY BUREAU OF SECURITIES
BRENNAN HAS FAILED TO COMPLY WITH THE TERMS OF A SUPERVISORY AGREEMENT. DURING THE PERIOD OF THE FIRST AND SECOND HEIGHTENED SUPERVISORY AGREEMENTS, BRENNAN RECEIVED COMMISSIONS FROM ACTIVITY IN NEW JERSEY CLIENT ACCOUNTS, EVEN THOUGH THIS PRACTICE WAS EXPLICITLY PROHIBITED BY HIS AGREEMENTS. BOTH BRENNAN AGREEMENTS STATE THAT "[F]AILURE TO COMPLY WITH THIS AGREEMENT SHALL BE DEEMED TO BE A VIOLATION OF N.J.A.C. 13:47A-14.16, WHICH ENTITLES THE BUREAU TO IMPOSE SANCTIONS."
Consent
Cease and Desist
Civil and Administrative Penalty(ies)/Fine(s)
$30,000.00
Regulatory 02/02/2010
NEVADA
RESPONDENT HAD BEEN SUSPENDED FROM ASSOCIATION WITH ANY BROKER, DEALER AND/OR FINRA MEMBER IN ANY PRINCIPAL CAPACITY FOR A PERIOD OF SIX (6) MONTHS, CONCLUDING AT THE CLOSE OF BUSINESS ON JUNE 20, 2010
Consent
Revocation
Regulatory 01/20/2010
NEW JERSEY BUREAU OF SECURITIES
BRENNAN IS THE SUBJECT OF AN ORDER OF A STATE SECURITIES REGULATOR DENYING HIS SECURITIES LICENSE. BRENNAN IS THE SUBJECT OF AN ORDER OF A SELF REGULATORY ORGANIZATION SUSPENDING HIM FROM A NATIONAL SECURITIES ASSOCIATION. BRENNAN HAS FAILED TO COMPLY WITH THE TERMS OF THE SUPERVISORY AGREEMENT.
Consent
Civil and Administrative Penalty(ies)/Fine(s)
$5,000.00
Undertaking
THE BUREAU CHIEF'S SUMMARY REVOCATION AND PENALTY ORDER ISSUED ON AUGUST 18, 2010 AGAINST BRENNAN BE AND IS HEREBY VACATED. BRENNAN MAY REGISTER WITH THE BUREAU AN AN AGENT SUBJECT TO AND CONDITIONED UPON THE EXECUTION OF A HEIGHTENED SUPERVISORY AGREEMENT AND PAYMENT OF A CIVIL MONETARY PENALTY.
Regulatory 11/13/2009
FINRA
FINRA BY-LAWS ARTICLE V, SECTION 2(C), FINRA RULE 2010 AND NASD RULES 2110 AND 3010 AND INTERPRETATIVE MATERIAL-1000-1: RESPONDENT KEVIN P. BRENNAN FAILED REASONABLY TO SUPERVISE REGISTERED REPRESENTATIVES WHO CONDUCTED AND OPERATED A SECURITIES BUSINESS FROM AN UNREGISTERED BRANCH OFFICE WITHOUT SUPERVISION AND IMPROPERLY SOLICITED POTENTIAL CUSTOMERS BY TELEPHONE IN CONNECTION WITH THE OFFER OF SECURITIES, MADE FALSE MISREPRESENTATIONS, INCLUDING UNWARRANTED PRICE PREDICTIONS, OMITTED MATERIAL FACTS, AND USED MISLEADING TELEMARKETING SCRIPTS THAT WERE NEVER APPROVED BY A REGISTERED PRINCIPAL. BRENNAN FAILED TO RESPOND TO WARNING SIGNS THAT THE REGISTERED REPRESENTATIVES WERE CONDUCTING SALES ACTIVITY OUTSIDE OF THE FIRM'S REGISTERED OFFICES. BRENNAN ALSO FAILED TO TIMELY AMEND HIS FORM U4 TO DISCLOSE MATERIAL INFORMATION.
Acceptance, Waiver & Consent(AWC)
Civil and Administrative Penalty(ies)/Fine(s)
$15,000.00
Suspension
ANY PRINCIPAL CAPACITY
SIX MONTHS
12/21/2009
6/20/2010
Customer Compliant 10/21/2008
CHURNING, EXCESSIVE COMMISSIONS, UNSUITABLE INVESTMENTS FAILURE TO SUPERVISE
$1,500,000.00
$60,000.00
Customer Dispute 09/30/2008
UNSUITABLE INVESTMENTS, UNAUTHORIZED TRADING, FAILURE TO SUPERVISE
$541,832.00
$50,000.00
